Today, “[d]ue to the unique issues presented in FCPA matters,” Deputy Attorney General Rod Rosenstein announced a new FCPA corporate enforcement policy published in a revision to the United States Attorneys’ Manual. The new policy effectively makes permanent the FCPA Pilot Program originally announced in April 2016 and increases the incentives for corporate self-disclosure by adding a “presumption” that DOJ will issue declinations when a company’s self-disclosure, cooperation, remediation, and disgorgement meet certain standards.
‘Enforcement 40’ for 2020
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