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New Article – Grading The DOJ’s “FCPA Corporate Enforcement Policy”


Bloomberg BNA’s White Collar Crime Report recently published my article “Grading the DOJ’s FCPA Corporate Enforcement Policy.”

The article can be downloaded here for free and address the following issues: (i) the obvious logical gap in the Corporate Enforcement Policy (CEP); (ii) how the CEP, both in terms of rhetoric and substance, is really nothing new; (iii) ten specific reasons why the corporate community should take the CEP with a grain of salt; and (iv) how the CEP falls short of accomplishing the laudable goals articulated by the DOJ compared to other alternatives previously advanced.

This is not the first took I took out my red pen to grade a DOJ FCPA policy announcement. See here for my 2012 article “Grading the Foreign Corrupt Practices Act Guidance” and here for my 2016 article “Grading the DOJ’s FCPA Pilot Program.”


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