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DOJ can significantly reduce the adverse consequences that accompany an investigations potentially endless period of uncertainty through a simple reform of its policy regarding when prosecutors should notify former targets that an investigation has been closed. Department statistics show that federal prosecutors take, on average, more than 400 days to reach a declination decision. During […]
… Companies that can demonstrate a truly proactive approach to anti-corruption compliance, both before a problem arises and after an allegation is received, can do much to help themselves in order to obtain the real golden carrot – the much-desired “declination” from the U.S. Department of Justice (“DOJ”) and similar treatment from the Securities and […]
3M discloses that DOJ and SEC will terminate their investigations into possible violations of the FCPA without taking any action.
How should we define “declination?”
FCPA guide references “dozens” of declinations over the past two years.