On November 29th, the Department of Justice unveiled a revised Foreign Corrupt Practices Act (FCPA) Enforcement policy that provides significant incentives for corporations to voluntarily self-disclose potential FCPA violations.
The new policy makes permanent many aspects of a pilot program started under the Obama Administration with one significant enhancement: a presumption of a corporate declination of criminal charges if a company voluntarily self-discloses misconduct and cooperates early and fully.
For more information, please see Crowell’s Client Alert.
For more information, contact: Kelly Currie, Stephen Byers, Paul Rosen, Alan W.H. Gourley, Cari Stinebower, Jared Engelking