Law360 (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. 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.
The FCPA Corporate Enforcement Policy
Originally formalized in November 2017 following a pilot program, the policy provides significant incentives to companies that voluntarily self-disclose FCPA violations, cooperate with the government, and appropriately remediate. Companies that self-disclose can...
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