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Expert Analysis

Clarifications Needed After DOJ's New FCPA Policy

By Derek Hahn, Dalal Hasan, Tom Hanusik and Stephen Byers (March 22, 2019, 4:29 PM EDT) -- The U.S. Department of Justice released revisions to the Foreign Corrupt Practices Act corporate enforcement policy on March 8, 2019.[1] While intended to clarify the DOJ's position on a number of hot-button issues, including its controversial stance on certain instant-messaging software, a closer look reveals that these changes fall short of answering several key questions faced by companies seeking cooperation credit in FCPA matters....

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