On April 5, 2016, the U.S. Department of Justice (DOJ) issued an Enforcement and Guidance Plan (Plan) concerning the Foreign Corrupt Practices Act (FCPA). While the new Plan could be interpreted as a novel departure from past precedent, careful analysis reveals that it does little to alter or clarify how the DOJ will review cases or reward companies for significant cooperation in addressing anti-corruption global issues.

Originally published in Inside Counsel on September 6th, 2016.