The First 6 Months Of FCPA Pilot Program: 10 Lessons

Law360, New York (October 12, 2016, 11:11 AM EDT) -- The U.S. Department of Justice's Foreign Corrupt Practices Act Pilot Program reached its six-month anniversary on Oct. 5, 2016. Since the program began, the DOJ has announced multiple corporate FCPA resolutions. While the U.S. Securities and Exchange Commission does not have an official FCPA pilot program, it too has been active in FCPA cases this year, often acting in concert with the DOJ on Pilot Program resolutions. With the first half-year of the Pilot Program in the books, it is useful to examine the FCPA enforcement activity undertaken by the DOJ and the SEC to see what lessons may be learned about how the program is working and what it means for practitioners and companies going forward....

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