Key takeaways

• 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.