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.
via DOJ Announces New FCPA Corporate Enforcement Policy – Lexology
