DOJ Announces FCPA Enforcement Pilot Program

Earlier this week, DOJ's Fraud Section released a guidance memorandum (the FCPA Enforcement Guidance Memorandum) outlining an FCPA pilot program that allows for fine reductions beyond what is available under the U.S. Sentencing Guidelines to companies that voluntarily self-disclose possible FCPA violations, fully cooperate with investigators, and implement timely and appropriate remediation, which we refer to here as the Pilot Program. The memorandum also discusses the increase in resources that DOJ will be devoting to FCPA investigations. This Client Update focuses on the Pilot Program.

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