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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.

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