The Department of Justice this month made a few minor adjustments to its Corporate Enforcement Policy that are worth a closer look, as these changes could impact when compliance officers and corporate counsel decide to self-report a potential Foreign Corrupt Practices Act violation.
After launching as a pilot program in 2016, the FCPA Corporate Enforcement Policy was made permanent in November 2017 giving compliance officers and corporate counsel greater transparency and consistency around how the Criminal Division’s Fraud Section measures and credits voluntary self-disclosure, cooperation, and remediation efforts in criminal matters.
