FCPA Policy Update On Trend With Greater DOJ Transparency

Law360 (November 26, 2019, 5:16 PM EST) -- The U.S. Department of Justice announced updates last week to its Foreign Corrupt Practices Act Corporate Enforcement Policy. While modest on their face, these changes are the most recent example of the DOJ's commitment to be more transparent in providing companies with greater incentives to self-disclose suspected FCPA violations.

The FCPA Corporate Enforcement Policy: Developing Incentives

Over the past several years, the DOJ has focused on providing companies with incentives to self-report potential FCPA violations, while also increasing transparency into its prosecution decisions, including the way in which it provides tangible benefits to companies that make self-disclosures.

The first official iteration...

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