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
Corporate resolution policy will provide greater clarity and predictability for companies that self-report and cooperate with DOJ.
Key Points:
..The new policy requires DOJ civil and criminal prosecutors to coordinate...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.
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Key Points:
- DOJ is reviewing and reevaluating numerous corporate enforcement policies, including the “Yates Memo,” the FCPA Pilot Program, and policies on corporate monitors.
- Policies will be codified in official...more