• The voluntary disclosure of a Foreign Corrupt Practices Act (FCPA) violation, “full cooperation” in an ensuing investigation, and timely and appropriate remediation, will create a presumption that the disclosing company...more
12/4/2017
/ Anti-Corruption ,
Attorney General ,
Cooperation ,
Corporate Fines ,
Department of Justice (DOJ) ,
Disgorgement ,
Federal Pilot Programs ,
Foreign Corrupt Practices Act (FCPA) ,
Forfeiture ,
Memorandum of Guidance ,
Remediation ,
Restitution ,
Self-Reporting ,
Substantial Aggravating Circumstances ,
Voluntary Disclosure
On September 9, 2015, the U.S. Department of Justice issued guidance regarding the prosecution of individuals in cases involving criminal and civil corporate wrongdoing. The first major policy memorandum issued since Attorney...more