On April 5, 2016, the Fraud Section of the U.S. Department of Justice's Criminal Division issued a much-awaited Enforcement Plan and Guidance ("Guidance") on the Foreign Corrupt Practices Act (FCPA or the "Act"). This Guidance lays out the framework for three key initiatives—the most notable of which is a pilot program that offers reduced-fine amounts and a declination of criminal charges in exchange for voluntary self-disclosure and cooperation by corporate offenders.
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