Hats off to the DOJ on new FCPA Corporate Enforcement Policy

By Thomas R. Fox

Thomas R. Fox (tfox@tfoxlaw.com) is the Compliance Evangelist.

In late November, the Department of Justice (DOJ) announced a new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement: the FCPA Corporate Enforcement Policy. It was the result of the DOJ review from the expiration of the one-year FCPA Pilot Program in April 2017. It not only assessed the Pilot Program, but made changes that make this new policy even more effective than the Pilot Program. In addition to the enforcement aspects of increasing the discount available to companies that met the requirements of the Pilot Program from a 50% to 100% discount, the DOJ made the presumption that companies would receive a full declination as the default response to meeting the prescripts of the new policy.

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