Skip to content

Menu

LexBlog, Inc. logo
NetworkSub-MenuBrowse by SubjectBrowse by PublisherJoin the NetworkGet StartedSubscribeSupport
Contact Us
Search
Close

The DOJ’s New FCPA Corporate Enforcement Policy: Dangling Presumptive Declination as an Incentive for Voluntary Disclosure

By Lucinda Low, Brittany Prelogar & Jessica Piquet Megaw on December 6, 2017
Email this postTweet this postLike this postShare this post on LinkedIn

As we discussed in last week’s blog post, on November 29, 2017, Deputy Attorney General Rod J. Rosenstein made remarks at the American Conference Institute’s 34th International Conference on the Foreign Corrupt Practices Act (FCPA) recognizing the success of the FCPA Enforcement Plan and Guidance (commonly referred to as the FCPA “Pilot Program”), which had been in effect since April 5, 2016.  In those remarks, Mr. Rosenstein also announced a revised FCPA Corporate Enforcement Policy.  The new policy, which has been formally incorporated into the US Attorneys’ Manual (USAM), and is specific to the FCPA, continues and builds upon aspects of the Pilot Program.  Its goal is to “increase the volume of voluntary disclosures” by providing additional transparency and certainty concerning the benefits of voluntary disclosure, full cooperation, and full and timely remediation, thereby “enhanc[ing] the [DOJ’s] ability to identify and punish culpable individuals.”  A transcript of Mr. Rosenstein’s remarks can be found here.

For more information, please see our advisory.

Photo of Jessica Piquet Megaw Jessica Piquet Megaw

Jessica Piquet Megaw focuses on compliance and investigations involving the Foreign Corrupt Practices Act (FCPA).

View Jessica’s full bio.

Read more about Jessica Piquet MegawEmail
  • Posted in:
    Corporate Governance and Compliance
  • Blog:
    International Compliance Blog
  • Organization:
    Steptoe LLP

Call us at 1-800-913-0988 or email sales@lexblog.com.

Facebook LinkedIn Twitter RSS
  • About LexBlog
  • The Field We Built
  • Our Beliefs
  • Our Team
  • Contact LexBlog
  • Disclaimer
  • Editorial Policy
  • Terms of Service
  • Get Started
  • Publishing Solutions
  • Compass
  • Submit a Request
  • Support Center
  • System Status
Copyright © 2026, LexBlog, Inc. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo