Law360, New York (February 23, 2012, 1:46 PM EST) -- Just as the U.S. Department of Justice is confronting a series of defeats in criminal Foreign Corrupt Practices Act cases against defendants who have put the DOJ to its burden of proof at trial, the government’s overall FCPA enforcement program is facing growing pressure to provide guidance about its priorities and expectations.
The DOJ announced in November 2011 that it would be releasing such guidance, but the nature and timing of the guidance remain uncertain. While the impact of DOJ’s recent setbacks in some of its most prominent FCPA cases also remains to be seen, if the sizeable corporate FCPA settlements...
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