The Justice Department’s foreign bribery team is shrinking amid a Trump‑ordered policy review, which could significantly weaken anti‑corruption enforcement.
At a Glance
- The DOJ’s Fraud Section has cut its Foreign Corrupt Practices Act team from 32 to about 15 prosecutors.
- Trump’s February executive order paused FCPA enforcement pending a 180‑day DOJ policy review.
- Many FCPA prosecutors have been reassigned to healthcare and marketplace fraud divisions.
- AG Pam Bondi directed prosecutors to shift toward drug‑cartel cases, deprioritizing foreign bribery.
- A recent DOJ memo lists foreign bribery below tariff evasion and government fraud in corporate enforcement priorities.
Enforcement Slashed
The decision to reduce the Foreign Corrupt Practices Act (FCPA) team reflects a broader move by the Trump administration to de-emphasize anti‑corruption efforts. In February, President Trump issued an executive order halting prosecutions under the FCPA until revised guidelines were introduced. At that time, the DOJ’s Fraud Section had approximately 32 prosecutors dedicated to tracing illicit payments to foreign officials. Today, that number has fallen to roughly 15—a reduction of more than 50 percent, according to Reuters reporting. This contraction demonstrates a sharp pivot in DOJ priorities.
Talent Exodus and Strategic Shift
As the 180-day review period began, many of the FCPA unit’s most experienced prosecutors departed or transferred to other divisions such as healthcare and marketplace fraud, further thinning the DOJ’s corruption bench. Attorney General Pam Bondi reportedly directed remaining prosecutors to pivot toward drug-cartel investigations—an area traditionally outside the FCPA unit’s scope, as detailed in Reuters’ February analysis.
Meanwhile, a recent DOJ memo ranked foreign bribery enforcement below other priorities, such as tariff evasion and domestic government fraud.
Watch a report: Foreign bribery enforcement shift explained.
Implications for Anti‑Corruption and Business
The FCPA, enacted in 1977, has long been a cornerstone of U.S. leadership in global anti‑corruption efforts. Its suspension, alongside drastic staffing cuts, raises concerns about Washington’s waning commitment to corporate accountability. Advocacy groups such as Transparency International warn that the rollback could embolden multinational firms to engage in unethical practices with impunity.
Supporters of Trump’s pause argue that FCPA enforcement has overreached, harming U.S. business competitiveness abroad. They claim the 180‑day review provides a chance to recalibrate enforcement policies to avoid excessive legal exposure for companies operating in high-risk markets.
Still, critics point to recent case dismissals, including an April decision to drop charges against former Cognizant executives, as early evidence of a lasting shift. If the DOJ’s reorganization becomes permanent, it could redefine the U.S. approach to anti‑corruption for years to come.
Risk and Opportunity
If the FCPA unit’s downsizing holds, enforcement capacity for foreign bribery cases could face long-term degradation. Companies may recalibrate their compliance strategies, especially in jurisdictions where corruption risks remain high. The DOJ’s forthcoming revised guidelines may offer clarity—but unless backed by resources and political will, they risk becoming symbolic. A strong, well-resourced FCPA unit is vital not only for deterring corruption, but also for upholding America’s role as a standard-bearer in global business ethics.
Whether the current changes signal temporary recalibration or enduring decline will become clear once the DOJ’s review concludes later this year.
