Gibson Dunn’s 2025 Year-End FCPA Update
Gibson Dunn’s 2025 Year-End FCPA Update frames 2025 as an “everything changed and nothing changed” year for anti-corruption: the U.S. government hit the brakes early, rewired the stated enforcement priorities mid-year, and still closed out 2025 with meaningful individual prosecutions and a marquee corporate resolution—while non-U.S. enforcers moved to fill perceived gaps.
January 18, 2026

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