Getting Specific About FCPA Compliance

Law360, New York (June 29, 2011) -- On April 8, 2011, the U.S. Department of Justice announced that it had reached a settlement with Johnson & Johnson and its subsidiaries for Foreign Corrupt Practices Act violations. Compared to prior FCPA settlements, the DOJ elaborated much more specific compliance measures that it expected Johnson & Johnson to take as part of the settlement.

When considered together with the decline in the number of corporate compliance monitors assigned since late 2010, the Johnson & Johnson settlement may signal that the DOJ is considering the use of enhanced compliance requirements in lieu of independent compliance monitors, even in some cases involving companies with multiple FCPA violations.

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Published In: Administrative Agency Updates, General Business Updates, Criminal Law Updates, International Trade Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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