By Michael Skopets and James Tillen (December 20, 2017, 12:49 PM EST) -- The second half of 2017 to date has seen increased enforcement activity related to the U.S. Foreign Corrupt Practices Act by both the U.S. Securities and Exchange Commission and the U.S. Department of Justice. Since our last article in August, the agencies have resolved more than 15 cases against corporations and individuals, issued several declinations, and initiated at least five new investigations under the statute. And in November, in the most prominent policy pronouncement regarding the FCPA under the Trump administration, the DOJ introduced the FCPA corporate enforcement policy, which replaces and incorporates elements of the department's FCPA pilot program by offering companies additional incentives to voluntarily disclose potential FCPA violations and providing greater clarity as to the consequences of self-disclosure....
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