Last April, the Criminal Division of the U.S. Department of Justice launched a one-year pilot program in the Fraud Section’s Foreign Corrupt Practices Act (“FCPA”) Unit. The pilot program, self-described as “building” on the Yates memorandum, provides structured incentives for companies to self-disclose, cooperate, and remediate with respect to FCPA violations. The remaining four months of the program before it expires promise to provide valuable information on several fronts.
via Last Four Months of DOJ’s FCPA Pilot Program Could Provide Important Signals | Subject to Inquiry
