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Unwrapping the new FCPA Corporate Enforcement Policy

Jaclyn Jaeger | December 4, 2017

After months of waiting, the compliance community finally has the answer it has been waiting for: The incentives of the FCPA Pilot Program are now permanent, under the guise of the revised and newly renamed FCPA Corporate Enforcement Policy.

In April 2016, Andrew Weissmann, chief of the Criminal Division’s Fraud section, issued a nine-page memo setting forth the details of a one-year FCPA enforcement pilot program initiated by the Fraud Section’s FCPA Unit. That pilot program stated that when a company has (1) voluntarily self-disclosed misconduct in an FCPA matter, (2) fully cooperated, (3) remediated in a timely and appropriate manner, and (4) disgorges all profits resulting from the FCPA violation, it then qualifies for the full range of potential mitigation credit.

On Nov. 29, in prepared remarks at the International Conference on the Foreign Corrupt Practices Act, Deputy Attorney General Rod...

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