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.”
