‘At Times of Stress, People Make Stupid Decisions’: Why FCPA Interlude Demands Greater Vigilance

Crystal R Jezierski April 24, 2025

With the DOJ pausing new FCPA cases and state regulators signaling they’re ready to step in, compliance leaders are navigating an uncertain, fast-moving landscape. In a recent article by Corporate Compliance Insights, Crystal Jezierski emphasizes that now is not the time to ease up. “My fear would be that people hear [about the pause] and just decide they don’t have to follow policies that are in place or that the policies in place no longer apply somehow,” she said.

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Crystal Jezierski wearing a black shirt and a red scarf smiles for the camera

Crystal R Jezierski

Senior Managing Director

Crystal R. Jezierski works with clients to manage governance and risk requirements and to design, implement, and lead compliance programs. Ms. Jezierski is a compliance expert and former compliance executive with 25 years of government and private sector experience. She has served as associate general counsel, assistant secretary for the U.S. Chamber of Commerce, senior vice president for Global Ethics at Walmart, a partner with the global law firm Baker McKenzie and as chief counsel for Oversight and Investigations with the Judiciary Committee of the U.S. House of Representatives.

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