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.” On Nov. 29, 2017, Deputy Attorney General Rod Rosenstein announced a revised FCPA corporate enforcement policy, which included three “enhancements” over the pilot program.
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. Although this article finds that the revised policy would have had no substantial effect on previous...
Stay ahead of the curve
In the legal profession, information is the key to success. You have to know what’s happening with clients, competitors, practice areas, and industries. Law360 provides the intelligence you need to remain an expert and beat the competition.
Access to case data within articles (numbers, filings, courts, nature of suit, and more.)
Access to attached documents such as briefs, petitions, complaints, decisions, motions, etc.
Create custom alerts for specific article and case topics and so much more!