All FCPA Corporate Enforcement Policy articles
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News BriefDOJ publishes voluntary self-disclosure policy for corporations
The Department of Justice codified a new policy regarding the voluntary self-disclosure of corporate misconduct, following recent announcements on the updates by agency officials.
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News BriefDOJ urges voluntary self-disclosure in corporate enforcement policy updates
The Department of Justice unveiled new incentives to encourage companies to voluntarily report violations of the Foreign Corrupt Practices Act, including steep discounts in monetary fines against businesses that self-disclose misconduct.
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Article
DOJ official hints at policy changes for off-channel communications, clawbacks
The Department of Justice is considering issuing new guidance regarding companies’ record-keeping obligations for employees’ use of personal cell phones to conduct corporate business, as well as executive compensation clawback policies.
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Article
Analysis: What to make of the DOJ’s rare FCPA opinion
The Department of Justice last week issued its first FCPA opinion procedure in six years. Experts weigh in on the ruling, the gap between opinions, and more.
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ArticleFCPA Resource Guide revision a gold mine for compliance officers
The first update to the SEC and Justice Department’s FCPA Resource Guide since it was published in 2012 includes several clarifications intended to benefit chief compliance officers and in-house counsel.
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ArticleAntitrust Division remarks on changes to model corporate plea agreement
The DOJ’s Antitrust Division last year quietly updated language contained in its “Model Annotated Corporate Plea Agreement,” as it applies to cooperation. Recent remarks provide more color around those changes.
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Article
DOJ revises export control and sanctions enforcement policy
The Department of Justice has revised its policy regarding voluntary disclosures of export control and sanctions violations.
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ArticleCorporate Enforcement Policy revisions impact FCPA disclosure
The Department of Justice this month made a few minor adjustments to its Corporate Enforcement Policy that are worth a closer look, as these changes could impact when compliance officers and corporate counsel decide to self-report a potential Foreign Corrupt Practices Act violation.
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ArticleHow compliance officers can shape enforcement in 2019
Compliance officers and in-house counsel will increasingly be expected to play a leading role in the Justice Department’s efforts to combat fraud in all areas in 2019.
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Blog
The ‘20 percent’ lesson learned from Panasonic Avionics
Compliance practitioners take note: Cooperating with FCPA investigators was literally worth millions to Panasonic Aviation.
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Article
Unwrapping the new FCPA Corporate Enforcement Policy
The Justice Department just announced its new FCPA Corporate Enforcement Policy. How different is it from the FCPA Pilot Program? And how will it change self-reporting misconduct?
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Blog
Announcing the new FCPA Corporate Enforcement Policy
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. More details on the revised FCPA Corporate Enforcement Policy are inside.