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 shuts down student loan firms over deceptive debt relief practices
The U.S. Federal Trade Commission (FTC) took action against a pair of student loan debt relief companies for allegedly deceiving borrowers. The move came despite the Trump administration’s broader efforts to roll back enforcement actions against businesses since taking office.
-
News BriefCoinbase faces a leftover SEC probe as crypto enforcement loses steam
After dismissing its lawsuit against the crypto exchange Coinbase in March, a second investigation into the exchange by the Securities and Exchange Commission has surfaced, according to a report from the New York Times. This comes as a bit of a surprise after the Trump administration has been scaling down ...
-
News BriefStates like New York, Pennsylvania stepping up to fill regulatory void left by federal agencies
As the Consumer Financial Protection Bureau steps back from its core mission of protecting American consumers, states like New York and Pennsylvania are stepping up to fill the regulatory void.