On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9, 2015 Yates Memorandum and administered within the FCPA Unit of the Criminal Division’s Fraud Section, the new pilot program is intended to reward voluntary reporting, cooperation and remediation by providing for substantially reduced fines, avoidance of a third-party corporate monitor or even declination of prosecution.
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