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Corporate Counsel › Voluntary Disclosure › FCPA Corporate Enforcement Policy (CEP)

WilmerHale

DOJ Announces First FCPA Enforcement Activity After Months-Long Pause

WilmerHale on

Over the past week, the U.S. Department of Justice (“DOJ”) unsealed its first Foreign Corrupt Practices Act (“FCPA”) enforcement action and issued its first declination since the pause in FCPA enforcement mandated by...more

Paul Hastings LLP

A Commitment to Transparency: Clarifying Key Enhancements to the U.S. Department of Justice’s Corporate Enforcement Guidance

Paul Hastings LLP on

Since September 2022, the U.S. Department of Justice (“DOJ” or “the Department”) has made a number of announcements signaling notable changes to its U.S. corporate enforcement policies. These changes include key revisions to...more

Vinson & Elkins LLP

Carrots Take Root: DOJ Significantly Revamps Corporate Enforcement Policy to Increase Incentives for Companies to Cooperate

Vinson & Elkins LLP on

In an apparent response to a downturn in corporate cases and criticism that its harsh rhetoric was chilling corporate cooperation, the Department of Justice (“DOJ”) recently announced significant changes to its policy on...more

Jones Day

DOJ Policy Increases Incentives for Self-Reporting of Potentially Willful Trade Violations

Jones Day on

The Situation: The U.S. Department of Justice ("DOJ") has issued guidance revising its 2016 voluntary disclosure policy to provide companies stronger incentives to voluntarily self-report apparent potentially willful trade...more

Orrick, Herrington & Sutcliffe LLP

DOJ Updates Its Approach to Encourage Voluntary Self-Disclosures of Export Control and Sanctions Violations

Orrick, Herrington & Sutcliffe LLP on

On December 13, 2019, the National Security Division (“NSD”) of the U.S. Department of Justice (“DOJ”) released a revised enforcement policy (“the Policy”) meant to encourage companies to voluntarily self-disclose potentially...more

The Volkov Law Group

DOJ Tweaks FCPA Corporate Enforcement Policy

The Volkov Law Group on

The Department of Justice recently announced updates to its Foreign Corrupt Practices Act Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding...more

BCLP

DOJ Further Incentivizes Voluntary Disclosure with Small Changes to FCPA Corporate Enforcement Policy

BCLP on

The Department of Justice tweaked its FCPA Corporate Enforcement Policy to further incentivize corporations to make voluntary disclosures. These small changes essentially acknowledge that companies in a very early stage of an...more

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