By Olga Greenberg, Scott Sorrels, Yvonne Williams-Wass and Jeffrey Bialos ( December 8, 2017, 12:00 PM EST) -- On Nov. 29, 2017, the U.S. Department of Justice kicked off the holiday season with a Christmas offering of sorts to companies subject to the U.S. Foreign Corrupt Practices Act with its announcement of a revised corporate enforcement policy.[1] The policy revision makes permanent the core elements of an Obama-era FCPA pilot program and also adds a key benefit to firms considering voluntary disclosures of FCPA violations — namely, that a presumption of no prosecution will apply to those companies that self-report such misconduct in a manner consistent with the DOJ's standards....
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