The path to DOJ cooperation credit: Analyzing recent FCPA cases
By 
Aaron Nicodemus2024-02-20T14:55:00
The Department of Justice (DOJ) has made voluntary self-disclosure of violations of the Foreign Corrupt Practices Act (FCPA) a point of emphasis in its description of mitigating factors affecting sentencing guidelines.
In January 2023, then-Assistant Attorney General Kenneth Polite Jr. unveiled new incentives to encourage companies to voluntarily self-report violations of the FCPA.
Under the agency’s revised corporate enforcement policy (CEP), it now considers reducing fines for criminal resolutions by 50-75 percent on the low end of U.S. sentencing guidelines for companies that self-disclose FCPA violations, cooperate with investigators, and remediate the misconduct.
THIS IS MEMBERS-ONLY CONTENT
You are not logged in and do not have access to members-only content.
If you are already a registered user or a member, SIGN IN now.
Related articles
-
News BriefBIT Mining changes business model, pays $10M fine to resolve FCPA violations
A publicly traded cryptocurrency mining company will pay $10 million and completely change its business model to one with “lower corruption risk” as part of a settlement over violations of the Foreign Corrupt Practices Act (FCPA), two regulators announced.
-
News BriefMilliporeSigma’s ‘extraordinary cooperation’ earns it DOJ declination
The Department of Justice declined to prosecute Massachusetts-based biochemical company MilliporeSigma for its “extraordinary cooperation” in uncovering a “rogue” employee’s scheme to procure and ship discounted products to China using falsified export documents.
-
OpinionHighlights from Compliance Week 2024
Compliance officers took to the main stage to share their experiences at Compliance Week’s 2024 National Conference, while other highlights included conversations around artificial intelligence and the modern challenges the industry is confronting.
More from Regulatory Enforcement
-
News BriefFTC sues Uber over deceptive subscriptions, a rare move for consumers by Trump officials
The Federal Trade Commission (FTC) filed a lawsuit against Uber, alleging the ride-hailing company signed customers up for its Uber One subscription without consent, then made it hard for them to cancel. The move marks the U.S. government’s latest broadside against big tech companies, and the first major action from ...
-
News BriefCFPB pullback signals further shift toward industry-friendly regulation
The U.S. Consumer Financial Protection Bureau continues to unravel amid pressure from Trump administration officials to shutter the agency. Not only has the agency informed its employees that it will no longer be a watchdog for the financial services industry, it has also laid off employees despite court orders blocking ...
-
News BriefTrump’s CFPB, dismissing Comerica case, continues to cut down Biden-era lawsuits
The Consumer Financial Protection Bureau dropped yet another consumer protection lawsuit against a bank or fintech provider since Donald Trump was sworn in as president in January. This time, it was with Comerica Bank.