News & Analysis as of

FCPA Corporate Enforcement Policy (CEP) Self-Reporting Cooperation

WilmerHale

Global Anti-Bribery Year-in-Review: 2023 Developments and Predictions for 2024

WilmerHale on

Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more

BakerHostetler

DOJ's Newly Revised Corporate Enforcement Policy Incentivizes Robust Compliance Programs, Cooperation and Remediation

BakerHostetler on

On Jan. 17, AAG Polite announced “the first significant changes” to the CEP since 2017. The policy revisions will apply to all corporate criminal matters handled by the Criminal Division and offer companies “new, significant,...more

Jones Day

DOJ Policy Increases Incentives for Self-Reporting of Potentially Willful Trade Violations

Jones Day on

The Situation: The U.S. Department of Justice ("DOJ") has issued guidance revising its 2016 voluntary disclosure policy to provide companies stronger incentives to voluntarily self-report apparent potentially willful trade...more

Vedder Price

DOJ Criminal Division Announces Major Change in Corporate Enforcement Policy

Vedder Price on

On March 1, 2018, the Criminal Division of the U.S. Department of Justice (“DOJ”) announced that it has expanded the scope of cases in which it will consider issuing a formal declination of criminal charges for a company that...more

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