Latest FCPA Deal Validates Pilot Program

Law360, New York ( July 25, 2016, 4:54 PM EDT) -- On April 5, the U.S. Department of Justice announced a novel new program to encourage companies to self-report violations of the U.S. Foreign Corrupt Practices Act. The so-called pilot program promises significantly reduced criminal fines to companies that voluntarily disclose FCPA transgressions, provided that they fully cooperate with the agency in the course of investigating the misconduct (including identifying all employees involved) and take swift remedial measures to avoid future problems. In the last three months, the DOJ has issued declinations — formal decisions not to prosecute — under the pilot program to three companies found to have violated the FCPA....

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