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.
THIS IS MEMBERS-ONLY CONTENT
You are not logged in and do not have access to members-only content.
If you are already a registered user or a member, SIGN IN now.
Related articles
-
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?
-
ArticleHow to establish an anti-corruption and anti-bribery compliance program
The U.K. unveiled a new Anti-Corruption Strategy in December 2025, just as the EU unveiled its first Anti-Corruption Directive. Both jurisdictions have signalled that they are keen to push back on rising risks of corruption. But many organizations have no formal anti-corruption measures. Where should compliance start?
-
ArticleGavin Proudley, SVP Risk & Compliance at Dow Jones, on compliance challenges from divergent rules and geopolitics
Diverging global rules, sanctions, and tariffs being “weaponized,” and more have made compliance complex even before the U.S. strikes on Iran. We asked Gavin Proudley, SVP Risk & Compliance at Dow Jones, what this means for compliance managers and how they can stay ahead of shifting geopolitics and tighter ...