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Announcing the new FCPA Corporate Enforcement Policy

Jaclyn Jaeger | November 29, 2017

Corporate America received an early holiday gift this year: The Department of Justice announced today that it will not only make permanent the incentives of its FCPA Pilot Program, but sweetened it with a bonus: the opportunity to receive a declination, rather than a discounted fine.

In April 2016, Andrew Weissman, chief of the Criminal Division’s Fraud section, issued a nine-page memo setting forth the details of a one-year FCPA enforcement pilot program initiated by the Fraud Section’s FCPA Unit. The pilot program does not apply to any other part of the Fraud Section, the Criminal Division, the U.S. Attorneys’ Offices, or any other part of the Justice Department.

Today, in remarks at the International Conference on the Foreign Corrupt Practices Act, Deputy Attorney General Rod Rosenstein noted that the incentives set forth in the FCPA Pilot Program “motivates and rewards companies that want to do the... To get the full story, subscribe now.