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Expert Analysis

FCPA Corporate Enforcement Policy: Pilot Program Redux

By Ryan Rohlfsen, Sarah Kimmer and Daniel Flaherty ( March 1, 2018, 12:15 PM EST) -- In March 2017, the U.S. Department of Justice extended the 2016 Foreign Corrupt Practices Act pilot program, pending a review of its "utility and efficacy."[1] On Nov. 29, 2017, Deputy Attorney General Rod Rosenstein announced a revised FCPA corporate enforcement policy, which included three "enhancements" over the pilot program.[2]...

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