FCPA Professor has been the place to be for the most comprehensive, candid and real-time information concerning the DOJ’s announcement on November 29th of a new “FCPA Corporate Enforcement Policy” aimed, in the words of the DOJ, “at providing additional benefits to companies based on their corporate behavior once they learn of misconduct.”
If you missed the eleven separate posts, no worries as this post collects in one place all posts related to the “FCPA Corporate Compliance Policy.”
- This post highlights the DOJ announcement of a new “FCPA Corporate Enforcement Policy”
- This post contains an analysis and highlights that if the DOJ is truly serious about “efficiently identifying and punishing criminal conduct and providing guidance and greater certainty for “companies struggling with the question of whether to make voluntary disclosures of wrongdoing,” non-binding DOJ guidance replete with discretionary terms and concepts is not the best answer.
- This post is an in-depth Q&A style post highlighting what you need to know from the DOJ’s “FCPA Corporate Enforcement Policy.”
- As highlighted here, presumptions are not new in the FCPA space. Rather the FCPA (the actual statute) has some presumptions.
- This post highlights how the DOJ has refused to provide clarity regarding the “aggravating circumstances” in its “FCPA Corporate Enforcement Policy.”
- As highlighted here, in the DOJ’s “FCPA Corporate Enforcement Policy,” the DOJ defined “declination.”
- This FCPA Flash podcast is a conversation with Leslie Caldwell about the DOJ’s “FCPA Corporate Enforcement Policy.” Caldwell previously served as the Assistant Attorney General of the DOJ’s Criminal Division and in this role was involved in implementing and promoting the DOJ’s April 2016 FCPA Pilot Program.
- This post highlights ten reasons why the corporate community should take the DOJ’s “FCPA Corporate Enforcement Policy” with a grain of salt.
- This post highlights what others are saying about the DOJ’s “FCPA Corporate Enforcement Policy”
- In the DOJ’s “FCPA Corporate Enforcement Policy,” companies are encouraged to do a root cause analysis and this post sets forth the best answer to the root cause analysis in many cases.
- As discussed in this post, Deputy Attorney General Rosenstein assumed causation when he called the FCPA Pilot Program successful.
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