Analysis

5 Takeaways From The 'New' FCPA Corporate Charging Policy

Law360, New York (November 29, 2017, 8:54 PM EST) -- A new policy guiding when corporations can avoid criminal charges under the Foreign Corrupt Practices Act for bribing foreign officials formalizes what had been a U.S. Department of Justice experiment and gives some amount of certainty for companies, experts say.

The FCPA corporate enforcement policy that Deputy Attorney General Rod Rosenstein announced on Wednesday is not a sea change, but it does bear some differences from the so-called FCPA pilot program the DOJ started in 2016. Experts saw five aspects of the new policy worth noting.

Continuity With the Pilot Program

In many ways, the policy codifies the pilot program that...

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