On March 20, 2025, the UK’s Serious Fraud Office, France’s Parquet National Financier, and Switzerland’s Office of the Attorney General announced the formation of the International Anti-Corruption Prosecutorial Task Force to combine resources on strategic priorities, cooperation, and “operational collaboration.” In the Task Force’s Founding Statement, the three international agencies emphasized that they will “stand firm” in their commitment to tackling bribery and corruption within national and international legal frameworks and invited “other like-minded agencies” to join them. In a press release, the Head of France’s Parquet National Financier referred to the 10 years of operational cooperation between the three agencies. 

To strengthen their existing collective effort in tackling international bribery and corruption, the Task Force promises to deliver a Leaders’ Group focused on the regular exchange of insight and strategy and a Working Group for devising proposals for cooperation on cases. Serious Fraud Office Director Nick Ephgrave reported that the Task Force should help ensure “there is no daylight between our agencies” preventing companies and individuals from taking advantage of any potential gaps between enforcement authorities. 

The formation of the Task Force follows Swiss authorities’ prosecution and conviction of a commodities trading firm and its former chief operating officer earlier this year. While not in direct response to the Trump Administration’s recent “pause” on FCPA enforcement as the Task Force was already underway, the Task Force signals a renewed commitment by international enforcement agencies to combat cross-border corruption and all three countries have wide-reaching anti-bribery legislation with jurisdiction to prosecute criminal conduct that occurs overseas, if there is a nexus with the prosecuting country. In all three countries, the investigating and prosecuting authorities have reaffirmed their willingness to continue monitoring companies to ensure that they have robust anti-bribery and corruption measures in place. As an example, since December 2024, there have been three Public Interest Judiciary Settlement Agreements signed with the French Parquet National Financier, whereas for the whole year of 2024, there were only four.

These developments underscore that while the United States may have temporarily paused its FCPA enforcement while it considers its overall anti-corruption program, the rest of the world has not, and several countries appear to be stepping into the temporary enforcement vacuum. This is another indication that multinational companies would be wise to continue their compliance efforts in the anti-corruption space.

Additional authors: A. Scott Bolden, Charles Hewetson, Daniel Kadar, and Anthony Todd.