Revised policies seek to end the Yates Memo’s all-or-nothing approach to corporate cooperation and should enable more timely and cost-efficient resolutions.
Key Points:
..Companies are eligible for criminal cooperation...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.
...more