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A closer look at the revised FCPA Corporate Enforcement Policy

Jaclyn Jaeger | March 26, 2019

The Department of Justice earlier this month made several notable revisions to its Corporate Enforcement Policy that are worth a closer look, as these changes could impact how compliance officers and general counsel choose to resolve Foreign Corrupt Practices Act matters.

On March 8, Assistant Attorney General Brian Benczkowski in remarks delivered at the ABA National Institute on White-Collar Crime Conference cryptically said the Justice Department was “currently in the process of updating the FCPA Corporate Enforcement Policy to bring it in line with current practice.” It was on that same day with little fanfare that a variety of revisions were made.

The original FCPA Corporate Enforcement Policy was implemented in November 2017 to give...

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