INTRODUCTION Contributed by: Eric Bruce and Justin Simeone, Freshfields US LLP
Looking ahead to 2026 developments For global practitioners, these developments raise many questions about the trajectory of global enforce - ment over the coming years. The new US enforce - ment guidelines indicate a clear shift in priorities. As of the release of this Guide, however, there are many open questions about what the application of the new guidelines will look like in practice. Will the DOJ return to regularly negotiating resolutions with significant penalties? Will it devote greater attention to individual prosecutions? Will it simultaneously focus greater attention on non-US companies? In turn, the new US guidelines have the potential to generate spillover effects in other countries. As of the release of this Guide, there are also many remaining questions about the practical effects these changes will have in other countries. Will other countries con - tinue to strengthen their own anti-corruption laws?
Will non-US authorities continue to devote additional resources to their anti-corruption enforcement actions without support from US enforcement authorities? If US authorities devote greater attention to enforce - ment actions against non-US companies, will foreign enforcement authorities, in turn, devote greater atten - tion to enforcement against US companies? Amid these many questions, what remains clear is that the trajectory of global anti-corruption efforts will remain in a state of transition in the years ahead. The following chapters provide valuable insights from expert practitioners who closely follow these devel - opments within their respective jurisdictions. We sin - cerely thank the authors for their excellent contribu - tions. We hope that practitioners will continue to find this Guide to be a valuable resource for understand - ing and navigating anti-bribery-and-corruption laws around the world.
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