DOJ's New FCPA Pilot Program Will Have Only Marginal Impact

Law360, New York (April 8, 2016, 4:44 PM EDT) -- Charles Duross

James Koukios On April 5, 2016, Assistant Attorney General Leslie Caldwell, who heads the Criminal Division of the U.S. Department of Justice, announced a new "FCPA pilot program" designed to motivate companies to voluntarily self-disclose Foreign Corrupt Practices Act-related misconduct. In making the announcement, AAG Caldwell disclosed a newly released policy document authored by Fraud Section Chief Andrew Weissmann titled "The Fraud Section's Foreign Corrupt Practices Act Enforcement Plan and Guidance."[1] 

According to the guidance, during a one-year pilot period effective April 5, 2016, companies that voluntarily disclose improper conduct to the Fraud Section's FCPA Unit, fully cooperate in...

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