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The New Department of Justice FCPA Corporate Enforcement Policy  

Author:  Claire N. Rajan.

Source: Volume 51, Number 09, May 1 2018 , pp.99-104(6)

Review of Securities & Commodities Regulation

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Building on a 2016 pilot program, the DOJ’s latest guidelines are an effort to provide more certainty for corporate defendants in FCPA cases as to the benefits from self-disclosure, cooperation, and remediation. The author discusses key components of the pilot program and the changes made in the current guidelines. She notes that while there is more certainty as to benefits, the DOJ reserves a measure of prosecutorial discretion.

Keywords: DOJ FCPA Self-Disclosure Pilot Program; Foreign Corrupt Practices Act Enforcement

Affiliations:  1: Allen & Overy.

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