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Feb. 9, 2026

The Foreign Corrupt Practices Act in 2026: A focus on cartels and national security interests

After a sudden pause and sweeping new guidance, the Trump administration's rebooted FCPA enforcement signals not retreat, but a strategic shift--one demanding renewed vigilance from globally active companies.

Ann Kim

Partner
Hogan Lovells

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Stephanie Yonekura

Partner
Hogan Lovells US LLC

Phone: (310) 785-4600

Email: stephanie.yonekura@hoganlovells.com

UCLA SOL; Los Angeles CA

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Rupinder K. Garcha

Senior Associate
Hogan Lovells

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Nick Castellano

Associate
Hogan Lovells

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The Foreign Corrupt Practices Act in 2026: A focus on cartels and national security interests
Shutterstock

If "all the world's a stage," then 2025 was Act One in the Trump administration's Foreign Corrupt Practices Act (FCPA) enforcement reboot. Legal experts predicted that the administration's FCPA enforcement efforts would largely parallel efforts of the first Trump administration. Instead, last year marked a stark shift in the administration's enforcement priorities. In February 2025, the administration...

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