FCPA Pilot Program leads to two 2017 declinations
The FCPA Pilot Program declinations we have seen so far in 2017 both make substantial additions to the precedent for how to avoid prosecution under the FCPA.
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When the U.S. Department of Justice announced a six-month enforcement pause of the Foreign Corrupt Practices Act (FCPA) in February, many speculated that the risks posed by bribery had been lowered. So when the DOJ said last week that it would resume launching FCPA investigations, it may just seem like ...