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No piling on requires global disclosure and cooperation

Tom Fox | June 18, 2018

Last month in remarks to the New York City Bar White Collar Crime Institute Deputy Attorney General Rod Rosenstein announced a new “anti-piling on” policy for global anti-corruption enforcement actions. This was the formal extension of the “one-pie” concept previously articulated  in 2016 by Kara Brockmeyer, then-chief of the FCPA Unit at the SEC, and Daniel Kahn, (then and current) head of the Justice Department FCPA Unit. 

The concept was that enforcement authorities were moving toward one total cost to anti-corruption violators that would be equitably split up by authorities where the corruption occurred or by the countries that had jurisdiction. Kahn noted that companies that self-disclosed to multiple regulators and extensively remediated, were more likely to garner credit with U.S. regulators for fines paid to overseas authorities. Now one-pie has morphed to anti-piling on and is enshrined in the U.S. Attorney’s Manual. 

But both one-pie and anti-piling on were...

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