FCPA Corporate Enforcement Policy: Pilot Program Redux

Law360 (March 1, 2018, 12:15 PM EST) -- In March 2017, the U.S. Department of Justice extended the 2016 Foreign Corrupt Practices Act pilot program, pending a review of its “utility and efficacy.”[1] On Nov. 29, 2017, Deputy Attorney General Rod Rosenstein announced a revised FCPA corporate enforcement policy, which included three “enhancements” over the pilot program.[2]

This article evaluates the potential effect of the revised policy’s enhancements by charting their departure from the pilot program and analyzing how criminal resolutions during the pilot program might have come out under the revised policy.[3] Although...
To view the full article, register now.
Law360 Pro Say Podcast
Check out Law360's new podcast, Pro Say, which offers a weekly recap of both the biggest stories and hidden gems from the world of law.