Since the launch of the FCPA Pilot Program in April 2016, the Justice Department has laid out the key guideposts for securing a declination to prosecute FCPA violations. Those guideposts include self-disclosure, cooperation with the government, disgorgement of illegally gained profits, and a genuine effort to remediate the internal conditions that led to the initial violation.

Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...