All FCPA Pilot Program articles
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ArticleUnwrapping 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.
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Article
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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Blog
CDM Smith probe ends in declination with disgorgement
The Fraud Section of the Justice Department’s Criminal Division last month issued its seventh declination under the FCPA Pilot Program, and the second under the Trump Administration. It was also the fourth declination with disgorgement, a developing FCPA enforcement trend.
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Blog
Caldwell: FCPA Pilot Program bringing more self-disclosures
When the FCPA Pilot Program was first announced, questions arose as to whether it would lead to an uptick in voluntary self-disclosures. According to Assistant Attorney General Leslie Caldwell, it has. Jaclyn Jaeger reports.
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Blog
Is a cup of coffee a reportable FCPA violation?
What’s next on the list of FCPA violations, a cup of coffee bought for a custom official while you await inspection? Tom Fox ponders that question after reading about Lennox International’s $475 facilitation payment Justice Department disclosure.
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Blog
Akamai Technologies dodges FCPA charges
A letter sent by the Department of Justice to Akamai Technologies reveals that the cloud services provider will not face an enforcement action in connection with a previously disclosed investigation into potential violations of the Foreign Corrupt Practices Act. It is the second declination this week issued under the new ...
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Article
CW2016: Practical implications of the Yates Memo
At Compliance Week 2016 last week, Jaclyn Jaeger covered the conversation between current and former enforcement officials, as well as compliance officers, on how the “Yates Memo” is affecting them from a real-world standpoint.
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Blog
New Justice Department guidance and FCPA Pilot Program
When the DoJ speaks, chief compliance officers should listen—especially when the talks center on enforcement. The agency has launched a pilot program for Foreign Corrupt Practices Act enforcement that details three areas of self-disclosure to be required by companies going forward. If a company meets all three areas, it could ...