Johnson & Johnson DPA-Part I: Self-Disclosure Reduces Fine

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The DPA between Johnson & Johnson and the DOJ is very instructive for all FCPA practitioners and provides a wealth of information on not only the specific facts of the case, but information on what the DOJ is currently viewing as the best practices of a FCPA compliance program and conduct which Johnson & Johnson engaged in during the investigative process which led to a dramatic reduction in the overall fine and penalty assessed against the company.

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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, Compliance Evangelist | Attorney Advertising

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