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- The New FCPA Pilot Program What Will It Mean In Practice
The New FCPA Pilot Program: What Will It Mean In Practice
April 21, 2016, Covington Alert
On April 5, 2016, the United States Department of Justice (“DOJ”), through the Criminal Division’s Fraud Section, announced a one-year Foreign Corrupt Practices Act (“FCPA”) enforcement pilot program (the “Pilot Program”) intended to motivate companies to voluntarily disclose FCPA-related misconduct and increase transparency around the Fraud Section’s approach to mitigation credit in corporate FCPA resolutions.
March 2, 2017, Covington Alert
The Fraud Section of the U.S. Department of Justice (“DOJ”) quietly released new guidance last month entitled “Evaluation of Corporate Compliance Programs” (the “Guidance”). While noting that “the Fraud Section does not use any rigid formula to assess the effectiveness of corporate compliance programs,” the eight-page Guidance outlines 11 “Sample Topics and Questions” that DOJ “has frequently found relevant in evaluating a corporate compliance program” in the context of a criminal investigation.
Winter 2017, Covington Alert
Anti-corruption enforcement is at a crossroads. In many respects, global anti-corruption enforcement has never been more active. The U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) in 2016 collected a total of $2.41 billion through FCPA enforcement actions against 27 corporate defendants, including through their share ...
Winter 2015, Covington Advisory