DOJ Announces New FCPA Policy - Including Hallmarks of an Effective Compliance Program

By Randi Morrison posted 11-30-2017 11:12 PM

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As has already been widely reported, yesterday, Deputy AG Rod Rosenstein announced a new FCPA Corporate Enforcement Policy aimed at further incentivizing and thus increasing voluntary self-disclosure, cooperation and remediation of FCPA wrongdoing. The new policy, which is incorporated into the US Attorneys' Manual, addresses (among a number of other noteworthy things) how the DOJ evaluates corporate compliance programs and spells out what Rosenstein characterized as "some of the hallmarks of an effective compliance and ethics program," including dedicated compliance resources and the compliance personnel reporting structure.

See these memos from WilmerHale and Skadden, and numerous additional memos and other resources here and here.

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