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.
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