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November 30, 2017
U.S. Department of Justice Announces New FCPA Corporate Enforcement Policy

On November 30, 2017, Cravath prepared for its clients a memo entitled “U.S. Department of Justice Announces New FCPA Corporate Enforcement Policy.” The memo discusses the implementation of a new FCPA Corporate Enforcement Policy to replace the closely watched FCPA Pilot Program launched in 2016. Although the new policy preserves many features of the FCPA Pilot Program, it looks to increase the rate at which companies self-report potential violations of the Foreign Corrupt Practices Act. It does so through the creation of a “presumption” that companies will receive a full declination of prosecution if they voluntarily self-disclose, remediate misconduct and cooperate with the DOJ’s investigation, though the DOJ will retain discretion in providing credit under the new program.

Please click here to read the memo.