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Leslie Caldwell


In this episode, Leslie Caldwell (Latham Watkins and former Ass't AG DOJ Criminal Division): (i) offers thoughts on the DOJ’s new “FCPA Corporate Enforcement Policy”; (ii) discusses whether the differences in the new policy (compared to the 2016 FCPA Pilot Program) were considered in 2016; (iii) addresses whether the new policy represents a de facto compliance defense; and (iv) opines whether the FCPA, as it reaches 40, has been successful in achieving its objectives.

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