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DOJ Revises FCPA Corporate Enforcement Policy
April 3, 2019, Covington Alert
In March 2019, the U.S. Department of Justice introduced several changes to the Foreign Corrupt Practices Act (“FCPA”) Corporate Enforcement Policy (“the Policy”). The Policy, originally incorporated into the Justice Manual in November 2017, outlines the Department’s position on mitigation credit that companies may receive for voluntary self-disclosure, full cooperation, and timely and appropriate remediation in FCPA matters. Since 2018, the Criminal Division of DOJ has been using the Policy as guidance outside of the FCPA context.
Most of the changes to the Policy formalize previously announced guidance or reflect recent Department practices. Two of the changes to the Department’s written position on remediation and cooperation are particularly notable.
January 30, 2020, Covington Alert
It has been another strong year in anti-corruption enforcement, with 2019 meeting or beating the high-water mark for enforcement across a number of measurements.
May 10, 2019, Covington Alert
On April 30, 2019, the U.S. Department of Justice (“DOJ”) Criminal Division released an updated version of the Evaluation of Corporate Compliance Programs (the “Guidance”), which serves as a reference for prosecutors in assessing corporate compliance programs in the context of DOJ investigations.
April 3, 2019, Covington Alert
In March 2019, the U.S. Department of Justice introduced several changes to the Foreign Corrupt Practices Act (“FCPA”) Corporate Enforcement Policy (“the Policy”). The Policy, originally incorporated into the Justice Manual in November 2017, outlines the Department’s position on mitigation credit that companies may receive for voluntary self-disclosure, full ...