A group of Senate Democrats has introduced legislation that would significantly extend the time prosecutors have to bring Foreign Corrupt Practices Act (FCPA) cases. The proposals come before midterm elections in November 2026, and follow months of debate over the Trump administration’s brief pause in FCPA enforcement earlier in 2025, and current DOJ enforcement priorities.
The proposed FCPA Reinforcement Act is relatively simple. It would extend the criminal statute of limitations for the FCPA’s anti-bribery provisions from five years to ten years. The change would apply prospectively, meaning it would not revive cases already older than five years when the law takes effect. The proposal also includes a sunset provision eight years after enactment.
In practical terms, the bill is designed to give prosecutors more time to investigate complex foreign bribery schemes. Cross-border corruption cases often involve multiple jurisdictions, foreign witnesses, shell companies, and financial records that take years to obtain through mutual legal assistance requests.
Yet the political context matters as much as the legal change. The legislation appears aimed at countering the perception that FCPA enforcement has weakened. By proposing to double the limitations period, Senate Democrats are signalling that corporate bribery enforcement should remain a central feature of US corporate accountability, and potentially an election issue.
How the FCPA pause turned bribery into a political football
In the early days of the second Trump administration, the Department of Justice announced a pause in certain FCPA enforcement.The pause lasted roughly four months. Critics argued that the move risked signalling to companies that anti-bribery enforcement was no longer a priority.
That concern galvanised political opposition, despite a return to FCPA enforcement actions since the 2025 pause. Nevertheless, Democrats are warning companies not to interpret the pause as a long-term shift in enforcement policy. Extending the statute of limitations would ensure that conduct occurring during any temporary slowdown could still be prosecuted years later.
The bill also fits within a broader pattern seen in US regulatory politics. When enforcement priorities change between administrations, lawmakers often introduce legislation that attempts to lock in certain enforcement tools or signal how policy might change after future elections. Despite the current five year limitations periods, the majority of FCPA enforcement actions look at conduct outside of the five year limitations periods given the various legal avenues to extend the limitations period. In addition, many companies under FCPA scrutiny agree to waive or toll statute of limitations to demonstrate cooperation.
In that sense, the Senate bill can be read partly as a policy marker. If control of Congress or the White House shifts in the future, the legislation suggests Democrats may seek stronger structural support for FCPA enforcement.
Despite the rhetoric, FCPA enforcement has not disappeared
In fact, the past year has seen an unusually active period for FCPA trials involving individuals. Within a relatively short span there have been multiple trials, including one in September 2025 and another in December 2025, with additional proceedings continuing into 2026.
In September 2025 a federal jury convicted Georgia businessman Carl Alan Zaglin for orchestrating hundreds of thousands of dollars in bribes to Honduran officials to secure government contracts worth roughly $10 million. He was later sentenced to eight years in prison and ordered to forfeit more than $2 million.
Just a few months later, in December 2025, a Texas jury convicted Ramón Alexandro Rovirosa Martínez for participating in a bribery scheme involving payments to employees of Mexico’s state-owned oil company to obtain contracts worth approximately $2.5 million.
More trials are expected in the coming months. When the DOJ issued its 2025 enforcement guidance, several individual FCPA trials were already scheduled and most of them continued despite the earlier enforcement review.
This level of courtroom activity is notable because historically many FCPA cases resolve through negotiated settlements rather than full trials. The recent run of prosecutions suggests that the enforcement pipeline built over several years of investigations remains active, despite the temporary pause in 2025.
At the same time, enforcement decisions are not limited to prosecutions and settlements. Declinations and deferred prosecution agreements also form part of the DOJ’s enforcement framework. The DOJ continues to reward companies that voluntarily disclose misconduct, cooperate with investigators, and remediate compliance failures.
In the first FCPA deferred prosecution agreement of the current administration, the DOJ concluded a corporate settlement in late 2025 with TIGO Guatemala, resolving allegations that the telecommunications company paid bribes to Guatemalan legislators in exchange for favourable legislation affecting its radiofrequency licences.
The case resulted in a significant financial penalty, including a $60 million criminal fine and more than $58 million in forfeiture, underscoring that the DOJ continues to rely on traditional enforcement tools such as DPAs when resolving corporate bribery cases.
Similarly, a declination in the Liberty Mutual FCPA case shows that Timely self-disclosure, genuine cooperation, and concrete remediation remain the keys to avoiding prosecution, and they are as relevant today as they were before.
Declinations and DPAs serve a dual purpose. They encourage companies to come forward when potential bribery is discovered, and they reinforce the DOJ’s expectations around effective compliance programs.
For compliance teams, the message is clear. Strong internal reporting systems and prompt investigations remain critical. Companies that can demonstrate a genuine culture of compliance stand a far better chance of receiving favourable treatment if issues arise.
The DOJ’s evolving enforcement priorities
Recent DOJ announcements also show that enforcement priorities are evolving rather than disappearing. The department has signalled an increased focus on corporate fraud and financial crime more broadly. Enforcement authorities are increasingly targeting schemes that involve complex financial manipulation, sanctions evasion, and national security risks.
At the same time, the DOJ has outlined updated corporate enforcement priorities designed to clarify expectations for compliance programs. These priorities emphasise risk-based compliance structures, strong internal controls, and meaningful board-level oversight.
The shift reflects a broader enforcement trend. Rather than focusing solely on bribery cases in isolation, prosecutors are increasingly examining how corruption intersects with other forms of corporate misconduct. For multinational organisations, this means anti-bribery compliance cannot operate in a silo. It must be integrated into wider financial crime prevention frameworks.
What this means for compliance teams
For companies operating internationally, the debate in Washington should not change the practical approach to anti-bribery compliance. FCPA enforcement remains alive and well. Prosecutors continue to pursue cases, negotiate corporate settlements, and reward voluntary disclosures where appropriate.
At the same time, the political debate around enforcement signals that anti-corruption policy could towards an even stricter application with increased timelines and limitation statutes, if Democrats regain control of Congress. For compliance professionals, the safest assumption remains the simplest one. Foreign bribery enforcement continues to be an enforcement priority and the underlying expectations have not changed. Companies are expected to maintain strong internal controls, conduct thorough due diligence on third parties, and respond decisively when misconduct is identified. Regardless of the politics, the fundamental compliance obligations under the FCPA remain firmly in place.
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