More corporate enforcement guidance geared to provide companies a path toward penalty reductions or declinations. Reiterated messages regarding the importance of investing in compliance. A slow year for Foreign Corrupt Practices Act (FCPA) enforcement. All these trends at the Department of Justice (DOJ) can be easily linked together as part of one larger narrative.
My guess at the result: The DOJ is gearing up for a lot of future “we warned yous.”
