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

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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.

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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 | Attorney Advertising

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