The US Department of Justice’s Civil Division on September 4 issued detailed internal guidance on how the Division should evaluate and handle inability-to-pay claims by entities. Acting Assistant Attorney General Ethan P....more
Recent statements by top US Department of Justice officials indicate that DOJ may consult the FCPA Corporate Enforcement Policy for guidance outside of the Foreign Corrupt Practices Act context in assessing whether a...more
Deputy Attorney General said he anticipates policy changes “in the near future” and suggested emphasis on individual accountability.
The US Department of Justice (DOJ) may soon announce changes to its policies for...more
The US Department of Justice plans to extend its FCPA Pilot Program, an initiative developed to encourage companies to self-report bribery violations and provide extensive cooperation in exchange for reduced penalties,...more
The penalties are potentially astronomical for entities with FCA exposure.
In addition to treble damages, the False Claims Act (FCA) provides for mandatory penalties for each false claim submitted “of not less than...more