Gibson Dunn Partners Note in Law360 That California May Pick Up the Slack on Foreign Bribery Enforcement

Article  |  April 15, 2025

Law360

Gibson Dunn partners Winston Chan (San Francisco), Patrick Stokes (Washington, D.C.), and Oleh Vretsona (Washington, D.C.) discuss California Attorney General Rob Bonta’s recent reminder to businesses operating in California that, despite President Trump pausing enforcement of the Foreign Corrupt Practices Act, making payments to foreign officials to obtain or retain business remains illegal. The Attorney General added that California may step up corruption-related enforcement if federal authorities’ priorities shift to other areas.

In view of these and other developments, the authors conclude that “companies would be well served by reviewing their compliance programs and calibrating their compliance-related risk assessments to mitigate against changing risk calculi and enforcement realities.”

Read their discussion in Law360 [PDF].