The US executive order halts new and existing foreign bribery investigations — but enforcement risk in the UK and Europe remains.

By Pamela Reddy, Nathan Seltzer, Clare Nida, Annie Birch, and Matthew Unsworth

On 10 February 2025, President Trump issued an executive order titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security” (the Order). Among other things, the Order pauses new prosecutions under the Foreign Corrupt Practices Act (FCPA) at the

By Dan Smith

On November 26, 2015, the UK Serious Fraud Office secured its first Deferred Prosecution Agreement against UK-based ICBC Standard Bank Plc for failure to prevent one of its sister companies from bribing Government of Tanzania officials, an offence under Section 7 of the Bribery Act 2010 (the “Failure Offence”).

Standard Bank agreed to pay approximately US$33 million in compensation, disgorgement of profits, penalties and costs. In addition, Standard Bank settled charges with the US Securities and Exchange Commission under an administrative order for an additional US$4.2 million penalty related to the same conduct. The US Department of Justice reportedly worked with the SFO in this matter.