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Best practices under the new FCPA Enforcement Policy

Tom Fox | December 5, 2017

Last week, the Department of Justice premiered a new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA Corporate Enforcement Policy and stated that it is now “incorporated into the United States Attorneys’ Manual.” The Policy has much to say to the compliance practitioner about what constitutes a best practices compliance program and how you should go about engendering one.

There are several different points to note about compliance programs under the new Corporate Enforcement Policy. The first is the incorporation of the 10 Hallmarks of an Effective Compliance Program through reference to...

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