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DOJ Declinations under FCPA Corporate Enforcement Policy

The Department of Justice’s (“DOJ”) policy regarding corporate enforcement of the Foreign Corrupt Practices Act (“FCPA”) has evolved in meaningful ways since 2016. While the policy developments themselves have been frequently...more

DOJ Criminal Division Announces Major Change in Corporate Enforcement Policy

On March 1, 2018, the Criminal Division of the U.S. Department of Justice (“DOJ”) announced that it has expanded the scope of cases in which it will consider issuing a formal declination of criminal charges for a company that...more

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