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DOJ Announces a Revised FCPA Corporate Enforcement Policy
30 November 2017
View Client Update
DOJ has announced a revised Policy on Corporate Enforcement of the FCPA, which offers presumption of declination to companies that self-disclose, fully cooperate, and timely remediate.
The new Policy takes the Pilot Program’s attempt to incentivize self-disclosure one step further, by more clearly delineating the benefits of self-reporting.
The revised Policy puts to rest any speculation that the Trump administration would retreat from its predecessor’s approaches to FCPA enforcement.
White Collar & Regulatory Defense
Andrew J. Ceresney
Andrew M. Levine
David A. O'Neil
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