The revised policy both clarifies and expands DOJ’s prior disclosure guidance.
On December 13, 2019, the United States Department of Justice (DOJ) revised its policy regarding voluntary self-disclosures (VSDs) of...more
Ruling holds that the government cannot use conspiracy and accomplice liability theories to reach foreign nationals that lack US ties.
Key Points:
..Non-resident foreign nationals who are not otherwise subject to direct...more
The revised FCPA Corporate Enforcement Policy signals DOJ’s emphasis on corporate voluntary self-disclosure, rewarding cooperating companies with a presumption in favor of declination and reductions in penalties.
...more
The extension of the program — which emphasizes voluntary self-disclosure of FCPA violations, raises considerations for corporate entities and individual executives.
The Department of Justice (DOJ) recently announced...more
The Guidance parallels the DOJ approach under the FCPA, but does not specify the value of mitigation and may create contradictory incentives.
The National Security Division (NSD) of the US Department of Justice (DOJ)...more
A serious shift of focus to individual accountability may impact traditional corporate defense and settlement tactics.
On September 9, 2015, the Department of Justice (DOJ) issued a set of guidelines that formally revise...more
FCPA Opinion Release provides insight into the jurisdictional reach of the FCPA and the level of due diligence the DOJ expects.
On November 7, 2014, the US Department of Justice (DOJ) issued its second and final...more