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In 1897, Samuel Clemens, the writer better known as Mark Twain, famously responded to press reports that he had died by sending a cable to a New York newspaper. "The report of my death was an exaggeration," Twain wrote. And he went on to live another 13 years. Recent commentary suggesting the end of federal anti-corruption enforcement may be similarly overstated.On Feb. 10, 2025, President Trump signed an executive order directing the Attorney General (AG) to pause all investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA) for 180 days while she reviews existing FCPA actions and issues new guidance for enforcement of the statute. Because the deadline can be extended at the AG's discretion, it is difficult to predict when the new guidance will be issued. Commentators nevertheless have wasted no time in predicting that the executive order and forthcoming guidance will spell the end of the FCPA as we know it.

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Late on February 10, President Trump ordered Attorney General Pam Bondi to “pause” new Foreign Corrupt Practices Act (FCPA) enforcement for 180 days while the U.S. Department of Justice (DOJ) refocuses criminal enforcement of the statute. The Executive Order is potentially among the most significant enforcement developments related to the FCPA in years. While the directive is specific to DOJ criminal enforcement of the FCPA, the order and recent memoranda issued by Attorney General Bondi signal shifting tides in the FCPA landscape. With more to come from DOJ, and possibly the U.S. Securities and Exchange Commission (SEC) under new leadership, companies should monitor new guidance before updating their FCPA compliance programs.

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Some years ago, while serving as the U.S. State Department’s first coordinator on global anticorruption, I visited a country in West Africa as part of my fieldwork. During my visit, an American businessman whose company was operating an important national enterprise told me about a government official who had solicited a bribe from him. When I asked how he got out of the situation, he said it was simple: “I told him that I wasn’t going to go to jail for him.”The law this businessman was not willing to break was the Foreign Corrupt Practices Act of 1977. U.S. President Donald Trump issued an executive order on February 10 that paused its enforcement, flying in the face of nearly 50 years of U.S. policy and practice. Trump alleges that FCPA rules are shutting U.S. companies out of lucrative business opportunities. But the evidence for this claim is weak and scant. In reality, a lighter approach to investigating and prosecuting foreign bribery by U.S. firms will ultimately hurt American businesses and taxpayers.

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As deepfakes become more advanced, businesses across all industries must reconsider their security strategies to address one of the most serious forms of identity fraud in today’s landscape. Over 1,200 respondents from the financial and payment sectors across seven European countries, including the UK, stated that account takeover is the leading type of fraud their customers are exposed to, followed by card payment fraud and phishing. The study, the first to focus on AI-driven identity fraud, highlights that deepfake technology has become one of the three most common types of identity fraud in the financial and payments sector across Europe. Deepfakes use Artificial Intelligence to create highly realistic digital forgeries. Their rapid growth is prompting urgent discussions about improving companies’ fraud prevention capabilities.

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The on-again, off-again Corporate Transparency Act (the “CTA”) mandatory beneficial ownership reporting is now back in effect. On February 18, 2025, the Texas federal district court in Smith v. United States Department of the Treasury lifted the injunction that it had earlier imposed enjoining enforcement of the CTA, thereby reinstating the CTA’s mandatory reporting requirements.

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In 1897, Samuel Clemens, the writer better known as Mark Twain, famously responded to press reports that he had died by sending a cable to a New York newspaper. "The report of my death was an exaggeration," Twain wrote. And he went on to live another 13 years. Recent commentary suggesting the end of federal anti-corruption enforcement may be similarly overstated. On Feb. 10, 2025, President Trump signed an executive order directing the Attorney General (AG) to pause all investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA) for 180 days while she reviews existing FCPA actions and issues new guidance for enforcement of the statute. Because the deadline can be extended at the AG's discretion, it is difficult to predict when the new guidance will be issued. Commentators nevertheless have wasted no time in predicting that the executive order and forthcoming guidance will spell the end of the FCPA as we know it. In the short term, they are probably right. 

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The 2025 State of Fraud Report reveals a critical inflection point in the financial industry’s battle against fraud, with 60% of institutions reporting increased fraud attacks affecting both consumer and business accounts. The landscape is dominated by sophisticated fraud rings, while digital channels (online or mobile banking) remain the primary vulnerability. In the face of rising threats, financial institutions report they are responding by implementing AI-powered fraud detection and investing in identity risk solutions in 2025. The report highlights a significant shift toward proactive fraud prevention, with organizations recognizing that reputational damage can be as devastating as direct financial losses.

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Woori Bank, which has been embroiled in unfair lending and various financial incidents, will prioritize strengthening internal controls this year. Starting last month, branch managers have directly participated in vault management and introduced an anonymous reporting system. Additionally, a new position called internal control specialist will be created to conduct occasional audits. According to a comprehensive report by ChosunBiz on the 9th, Woori Bank has recently established a new position called internal control specialist. Personnel assigned to this role will be selected from branch managers with expertise in the operational processes of bank branches. The internal control specialist will be responsible for the effective internal control activities of the headquarters' sales organization. By having the internal control specialist conduct periodic audits, which were previously carried out by the branches themselves, the intention is to enhance the effectiveness and professionalism of the audits.

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Contact: Mr.Nikolai Triffet 

Email: nikolai@icib.org

Contact: Mr Nereo Guzman Mendoza

Email: nguzman@businesssolutionvalley.com

Tel: +52 811 181 3514

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Control Quote

A man’s emotions are what define him, control is the hallmark of true strength. To lack feeling is to be dead, but to act on every feeling is to be a child.

Brandon Sanderson