Bass, Berry & Sims attorneys Thad McBride and Chris Climo provided commentary for an article in Corporate Compliance Insights outlining the top stories of 2025 by sharing insights on tariffs, the Foreign Corrupt Practices Act (FCPA) and the Corporate Transparency Act (CTA).
Thad offered insight on the Trump administration’s sweeping tariffs, calling “tariff” the word of the year, and the rollercoaster of enforcement under the FCPA this past year.
Speaking further about corporate compliance and enforcement, Thad addressed the uncertainty on federal enforcement, saying “There are rumblings from some states, most notably California, that they may try to fill the breach and more aggressively prosecute bribery and corruption in violation of state law. Several countries in Europe have likewise pledged to strengthen their own anti-bribery and anti-corruption enforcement efforts. At the moment, all this appears to be a drop in the bucket — and perhaps a leaky bucket at that.”
Chris discussed the tumultuous decision by the U.S. Treasury Department to revise the CTA rules such that they no longer apply to “U.S. Persons” or companies founded in the United States. Noting that a resurrection of the CTA’s broad application on the federal level is unlikely under the current administration, Chris drew attention to the New York LLC Transparency Act, a similar law set to take effect in New York state in 2026. While a bill to amend the state law to “contemplate the changes in CTA reporting and enforcement at the federal level” has passed the state house, it has yet to be signed by Gov. Kathy Hochul, said Chris.
The full article, “Top Stories of 2025,” was published by Corporate Compliance Insights on December 10 and is available online.