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.
‘Enforcement 40’ for 2020
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