The initial months of the current US administration have prompted a significant transformation in American enforcement priorities. These contrast with the established priorities of European countries and have significant implications for global businesses. Divergence and new risks in the areas of anti-corruption enforcement, Cartels, tariffs, and international sanctions will have a significant impact on businesses operating across transatlantic markets.

We covered:

• The FCPA pause and what's next - The implications of the DOJ's pause in corporate enforcement under the Foreign Corrupt Practices Act, and what might now take its place in US enforcement priorities.
• Increasing anti-corruption enforcement risk in Europe - Signs of renewed activity, including: the establishment of a new cross-border enforcement taskforce; a new wave of anti-corruption controls assessments by the French AFA; and indications from the Director of the UK SFO that "if the Americans are not in a position to prosecute, and there's a nexus to the UK and it's a bribery case, then we will seek to bring it here", alongside new efforts to encourage corporate self-reporting.
• Cartels and trade policy - How US designations of drugs Cartels affect companies doing business in LATAM, and the potential for other jurisdictions to follow suit.  
• Customs fraud and export controls - How US tariffs and other jurisdictions retaliatory measures may lead to growing enforcement and regulatory risks, including in relation to false claims, customs violations and export control issues in both the US and Europe.
• Sanctions enforcement and divergence - Key issues arising from a widening gap between US and EU/UK sanctions policy and enforcement approaches.