Corporate America received an early holiday gift this year: 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, rather than a discounted fine.

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Jaclyn Jaeger is a freelance contributor to Compliance Week after working for the company for 15 years. She writes on a wide variety of topics, including ethics and compliance, risk management, legal,...