DOJ Attempts to Encourage Corporate Self-Disclosures with the Announcement of a One-Year FCPA Pilot Program

By | Health Law Update | May 3, 2016

Pursuing a classic “carrot and stick” approach to incentivizing corporate self-disclosure of the Foreign Corrupt Practices Act (FCPA) violations and individual wrongdoing connected to FCPA violations, the DOJ Fraud Section announced a new FCPA pilot program aimed at providing transparency into the benefits of self-disclosing FCPA violations, and the consequences of not self-disclosing. 

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DOJ Seeks to Boost Voluntary Disclosures Through FCPA Pilot Program

By | White Collar Briefly | April 7, 2016

In a move that follows long-standing complaints from the corporate community and the FCPA defense bar concerning the Government’s vague assurances of “cooperation credit” in FCPA resolutions for self-reporting companies, on April 5, 2016, DOJ officials announced a new one-year FCPA “pilot program” that outlines a concrete set of standards defining what constitutes cooperation and what credit companies can expect to earn for that cooperation.

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