Don't Start Bribing Foreign officials.

President Trump has issued an executive order directing the US Attorney General to "pause" enforcement of the Foreign Corrupt Practices Act (the FCPA) and also "ordering revised, reasonable enforcement guidelines" of the FCPA. The FCPA, among other things, prohibits bribing foreign officials. Companies would be well-advised to continue to adhere to the FCPA's requirements: 

- this executive order is susceptible to successful judicial challenge, either in whole or in part; and

- the FCPA is still the law: an executive order cannot nullify a valid Act of Congress.