The revised FCPA Corporate Enforcement Policy signals DOJ’s emphasis on corporate voluntary self-disclosure, rewarding cooperating companies with a presumption in favor of declination and reductions in penalties.
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The extension of the program — which emphasizes voluntary self-disclosure of FCPA violations, raises considerations for corporate entities and individual executives.
The Department of Justice (DOJ) recently announced...more
The Guidance parallels the DOJ approach under the FCPA, but does not specify the value of mitigation and may create contradictory incentives.
The National Security Division (NSD) of the US Department of Justice (DOJ)...more
A serious shift of focus to individual accountability may impact traditional corporate defense and settlement tactics.
On September 9, 2015, the Department of Justice (DOJ) issued a set of guidelines that formally revise...more