PODCAST DISCUSSION: Three weeks after returning to the White House, U.S. President Donald Trump signed an executive order on February 10 directing the Justice Department to pause prosecutions of Americans accused of bribing foreign government officials while trying to win or retain business in their countries. Trump's order pauses enforcement of the nearly half-century-old Foreign Corrupt Practices Act (FCPA) and directed Attorney General Pam Bondi to review current and past actions related to the law and prepare new guidelines for enforcement. The law, enacted in 1977, prohibits companies that operate in the United States from bribing foreign officials. Over time, it has become a guiding force for how American businesses operate overseas. "It's going to mean a lot more business for America," Trump told reporters while signing the order in the Oval Office at the signing. Interestingly enough, Trump wanted to strike down FCPA during his first term in office. Calling it a "horrible law" and claiming it made the US the subject of the world’s ridicule and derision. Anti-corruption watchdog Transparency International said the FCPA made the US a world leader in addressing corruption. Trump's executive order "diminishes - and could pave the way for completely eliminating - the crown jewel in the U.S.'s fight against global corruption," Gary Kalman, executive director of Transparency International U.S. said in a statement. In 2024, the Justice Department and the Securities Exchange Commission filed 26 FCPA-related enforcement actions, and at least 31 companies were under investigation by year end, the White House factsheet said. In the initial segment, Philip Rohlik chats with “Regulatory Ramblings” host Ajay Shamdasani about what the Trump administration’s actions will mean for the fight against bribery and corruption in Hong Kong, Greater China and APAC writ large. They discuss the possibility that with less FCPA enforcement, the UK Bribery Act (2010) might fill the void to some extent – while acknowledging the British Serious Fraud Office lacks the resources of the USDOJ to make extraterritorial enforcement a reality. Philip also shares his advice on what he would tell compliance officers and in-house/general counsel at banking or financial institutions or major corporation sitting in Hong Kong, Singapore or Beijing. Hint: now is not the time to relax. We then turn to the lengthier conversation portion of the broadcast where we look at some of the more global, macro-level effects of President Trump’s recent executive order. Tom and Malcolm share their visceral responses when they first heard the announcement the administration would halt FCPA enforcement, with Tom averring why Trump took so long because he had raised similar concerns during his first term (2017-21). They share their concerns about what it will mean for the global fight against bribery and corruption, while acknowledging the limitations of the UK Bribery Act. Still, mainkland China’s anti-corruption legislation is worth looking at as well. The conversation concludes with Malcolm and Tom giving their advice to the legal and compliance professionals serving financial firms and multinational corporates in Asia, the Mideast and the world more generally. They concur that now is not the time to slack off in terms of anti-graft efforts. The FCPA, they conclude, is still a powerful tool. Given the vindictive and transactional nature of the current president, we just might expect selective enforcement of the Act under his administration. Indeed, it might be inevitable given past experience.