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Yates and Caldwell Lay Out Their FCPA Expectations

Tom Fox | November 20, 2015

This week both Deputy Attorney General Sally Yates and Assistant Attorney General Leslie Caldwell gave remarks about what they, and more importantly the Justice Department overall, now expect from companies that want to receive as much credit as possible if they are embroiled in a Foreign Corrupt Practices Act investigation.

These comments made clear that real, tangible benefits exist to following their remarks so that a company can work towards the best result possible: a declination to prosecute the company.

While this information is not rocket science—or really even new information—both Yates and Caldwell have packaged it in a way that it is clear and direct. It should be the guidepost for any compliance officer who finds himself or herself in a quandary about the steps to take with the U.S. government if an FCPA allegation is raised inside an organization. The bottom line is when these ladies talk FCPA enforcement and compliance, you should pay heed.


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