On March 20, 2025, the United Kingdom’s Serious Fraud Office (“SFO”), France’s Parquet National Financier (“PNF”), and Switzerland’s Office of the Attorney General (“OAG”) signed a founding statement to establish a new International Anti-Corruption Prosecutorial Taskforce.[1] The new taskforce will include a Leadership Group to exchange insight and strategy, as well as a Working Group focused on strengthening collaboration and cooperation in anti-corruption cases.[2]
The announcement comes just weeks after U.S. President Trump issued an Executive Order pausing enforcement of the Foreign Corrupt Practices Act (“FCPA”) for 180 days pending the issuance of revised guidance from the U.S. Department of Justice (“DOJ”).[3] A number of prior FCPA resolutions have involved complex cross-border investigations fostering collaboration with many foreign authorities, including several notable coordinated resolutions with the SFO, PNF, and OAG. These included, among others, the $3.9 billion global resolution involving Airbus in 2020 between the DOJ, PNF, and SFO, as well as the $1.1 billion global resolution involving Glencore in 2022 between the DOJ, SFO, and Brazilian authorities.[4] Separately, the SFO and PNF have established their own joint investigations in recent years.
The UK, Switzerland, and France each has legislation that enables national authorities to investigate and prosecute international corruption.[5] Over the years the taskforce members have pursued a number of enforcement tools similar to those employed in the U.S. to better detect, punish, and deter corruption. The SFO, for instance, is considering a whistleblower reward system similar to the U.S. Securities and Exchange Commission or DOJ whistleblower award program,[6] and the Judicial Affairs Committee of the Swiss Parliament—in collaboration with law enforcement authorities—is exploring the possibility of utilizing deferred prosecution agreements for white collar enforcement.[7] In the same vein, the PNF’s most recent corporate enforcement guidelines seek to provide concrete incentives for companies to promptly self-report potential misconduct, fully cooperate with the PNF, and appropriately remediate.[8]
In addition, the anti-corruption legislation in place in each of the taskforce’s home jurisdictions is, in certain regards, broader than the FCPA. For instance, the UK Bribery Act and French “Sapin II” anti-bribery law go beyond the FCPA by prohibiting “private corruption”—that which does not involve a foreign official[9]—and do not provide an exception for “facilitation payments.”[10]
The signed commitment previews further potential expansion involving authorities from other countries, stating, “We will, by our mutual agreement, invite other like-minded agencies involved in tackling international bribery and corruption to join the Taskforce.”[11]
Despite the temporary pause in FCPA enforcement while the Trump administration issues revised guidance, this announcement demonstrates that it continues to be prudent for companies to remain focused on maintaining the effectiveness of their existing compliance programs and investigating alleged misconduct. International authorities have increased their enforcement activity and investigative capacity over the last several years and may be even more encouraged to open new investigations given the current state of enforcement in the U.S.[12] The new taskforce is yet another demonstration of the commitment by international law enforcement agencies to investigating and prosecuting anti-corruption violations going forward.
[1] International Anti-Corruption Prosecutorial Taskforce, Founding Statement (Mar. 20, 2025), https://assets.publishing.service.gov.uk/media/67dc0bb3931ea30d1b7ee33d/International_Anti-Corruption_Prosecutorial_Taskforce.pdf.
[2] Id.
[3] Lisa Vicens, David Last, et al., President Trump Issues Executive Order Pausing FCPA Enforcement and Directs
Revision of Enforcement Guidelines (Feb. 12, 2025), https://www.clearygottlieb.com/-/media/files/alert-memos-2025/executive-order-pauses-fcpa-enforcement-and-directs-revision-of-enforcement-guidelines.pdf.
[4] U.S. Dep’t of Justice, Glencore Entered Guilty Pleas to Foreign Bribery and Market Manipulation Schemes (May 24, 2022), https://www.justice.gov/archives/opa/pr/glencore-entered-guilty-pleas-foreign-bribery-and-market-manipulation-schemes (updated Feb. 6, 2025). U.S. Dep’t of Justice, Airbus Agrees to Pay over $3.9 Billion in Global Penalties to Resolve Foreign Bribery and ITAR Case, (Jan. 31, 2020) https://www.justice.gov/archives/opa/pr/airbus-agrees-pay-over-39-billion-global-penalties-resolve-foreign-bribery-and-itar-case (updated Feb. 6, 2025).
[5] U.K. Serious Fraud Office, UK, France and Switzerland Announce New Anti-Corruption Alliance, (Mar. 20, 2025), https://www.gov.uk/government/news/uk-france-and-switzerland-announce-new-anti-corruption-alliance.
[6] “RUSI, our hosts tonight, are conducting research on the idea of incentivising whistleblowers. I think we should pay whistleblowers. If you look at the example of the United States of America, their system allows that . . . I would invite us to think about whether or not we want to consider incentivising whistleblowers, it has many benefits.” Nick Ephgrave QPM, Speech at RUSI (Feb. 13, 2024), https://www.gov.uk/government/speeches/director-ephgraves-speech-at-rusi-13-february-2024. The DOJ launched its own Whistleblower Awards Pilot Program in August 2024. Lisa Vicens, David A. Last, Andres Felipe Saenz, and Sarah Pyun, Two Enforcement Developments: DOJ Launches Whistleblower Awards Pilot Program and Amendments to the Foreign Extortion Prevention Act Are Passed into Law (Aug. 6, 2024), https://www.clearygottlieb.com/news-and-insights/publication-listing/two-enforcement-developments-doj-launches-whistleblower-awards-pilot-program-and-amendments-to-the-foreign-extortion-prevention-act-are-passed-into-law.
[7] Postulat 25.3028, Commission des Affaires Juridiques Conseil des États, Examen de l’Instrument de Procédure Pénale que Constitue l’Accord de Poursuite Différée, (Feb. 25, 2025) https://www.parlament.ch/en/ratsbetrieb/suche-curia-vista/geschaeft?AffairId=20253028.
[8] Guillaume de Rancourt, Amélie Champsaur, et al., France Revises Internal Investigation and Corporate Enforcement Guidelines, Cleary Gottlieb, (Apr. 13, 2023), https://www.clearygottlieb.com/-/media/files/alert-memos-2023/france-revises-internal-investigation-and-corporate-enforcement-guidelines.pdf.
[9] UK Bribery Act 2010 c. 23, General Bribery Offences, §§ 1-5. Law No. 2016-1691 of Dec. 9, 2016, on transparency, the fight against corruption and the modernization of economic life (“Sapin II”), Art. 21.
[10] U.K. Ministry of Justice, The Bribery Act 2010: Guidance 18, https://assets.publishing.service.gov.uk/media/5d80cfc3ed915d51e9aff85a/bribery-act-2010-guidance.pdf. Agence Française Anticorruption, The Issue of Facilitation Payments, (Oct. 2023), https://www.agence-francaise-anticorruption.gouv.fr/files/files/The%20issue%20of%20facilitation%20payments.pdf.
[11] International Anti-Corruption Prosecutorial Taskforce, Founding Statement (Mar. 20, 2025), https://assets.publishing.service.gov.uk/media/67dc0bb3931ea30d1b7ee33d/International_Anti-Corruption_Prosecutorial_Taskforce.pdf.
[12] Lisa Vicens, David Last, et al., President Trump Issues Executive Order Pausing FCPA Enforcement and Directs Revision of Enforcement Guidelines, Cleary Gottlieb (Feb. 12, 2025), https://www.clearygottlieb.com/-/media/files/alert-memos-2025/executive-order-pauses-fcpa-enforcement-and-directs-revision-of-enforcement-guidelines.pdf.