All Pilot Program articles
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ArticleThe evolution of FCPA enforcement
Compliance Week guest columnist Tom Fox writes about the Foreign Corrupt Practices Act’s journey from 2012 through today.
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Article
Distilling lessons from the uptick in FCPA declinations
As the number of FCPA declinations is up, all indicators point to a general desire on the part of the DoJ and SEC to clear out old cases and re-evaluate which ones to pursue.
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Blog
How Hui Chen prompted an evolution in compliance at the DoJ
Hui Chen’s time as compliance counsel at the DoJ’s Fraud Section was short and eventful and did a lot to move the needle on how the DoJ views corporate compliance programs.
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Article
Distilling lessons from the FCPA Pilot Program
A year after the DoJ launched its FCPA pilot program, companies are gaining much-valued insight on how to self-disclose and cooperate with the Criminal Division’s Fraud Section.
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Article
New leadership, similar enforcement agenda
Amid plenty of public turmoil in the Trump administration’s early days, the enforcement agendas of both the DoJ and the SEC remain fundamentally unchanged.
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Blog
Linde FCPA probe ends in DoJ declination
The Department of Justice closed its investigation into industrial-gas supplier Linde for alleged violations of the Foreign Corrupt Practices Act without bringing an enforcement action, making it the first public declination under the Trump Administration.
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Blog
What’s to come of the Pilot Program?
The countdown begins for when the compliance community will soon find out the fate of the Pilot Program initiated last year by the Criminal Division’s Fraud section. Until then, “the program will continue in full force until we reach a final decision on those issues,” Acting Assistant Attorney General Kenneth ...
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Blog
Want evidence about the FCPA Pilot Program?
Do you want to see evidence of the effectiveness of the Justice Department FCPA Pilot Program? Read on ...
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Article
Carrots and sticks: A closer look at the FCPA Pilot Program
The Department of Justice has churned out a brief, but valuable, piece of guidance setting forth the details of a one-year FCPA enforcement pilot program, providing companies with much needed and long-awaited transparency into how the Criminal Division’s Fraud Section measures and credits voluntary self-disclosure and cooperation in FCPA investigations. ...