How the DOJ Looks at Compliance Programs in an Enforcement Action-Part I

more+
less-

Although often discussed in Deferred Prosecution Agreements (DPAs) or Non-Prosecution Agreements (NPAs), most compliance practitioners are not familiar with one of the most important sources of Department of Justice (DOJ) policy regarding the charging of corporations under the Foreign Corrupt Practices Act (FCPA). This source is found in the United States Attorney’s Manual section, entitled “Principles of Federal Prosecution of Business Organizations” (“the Principles”). However, there is an excellent discussion found on this issue in the January 2012 publication of “Complying with the Foreign Corrupt Practices Act: A Practical Primer” (“the Primer”), published by the ABA Criminal Justice Section, Global Anti-Corruption Task Force.

LOADING PDF: If there are any problems, click here to download the file.


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.

© Thomas Fox, Advanced Compliance Solutions | Attorney Advertising

Written by:

more+
less-

Advanced Compliance Solutions on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×
Loading...
×
×