FCPA Pilot Program: Is Voluntary Self-Disclosure the New Key to Mitigating Corporate Liability?

Earlier this year, the US Department of Justice announced a one-year pilot program under which US corporations could mitigate their own liability for violations of the Foreign Corrupt Practices Act (FCPA) by voluntarily self-disclosing FCPA violations within their organization, in addition to fully cooperating with DOJ investigations and taking steps to remediate any misconduct.

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LATAM Airlines Pays $22 Million to Settle FCPA Allegations

On Monday, Chile-based airline LAN Airlines SA (now operating at LATAM Airlines Group) entered into a $22 million agreement with the U.S. Securities and Exchange Commission (SEC) and the Department of Justice (DOJ), to settle allegations that it violated the Foreign Corrupt Practices Act (FCPA).

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DOJ’s First Corporate Enforcement Action Under Pilot Program

By | Subject to Inquiry | July 5, 2016
DOJ’s First Corporate Enforcement Action Under Pilot Program

In April 2016, the Department of Justice (DOJ) announced its Foreign Corrupt Practices Act Enforcement Plan and Guidance, which includes a one-year pilot program to incentivize individuals and companies to voluntarily self-disclose Foreign Corrupt Practices Act-related (FCPA) misconduct, cooperate with DOJ investigations and remediate controls and compliance programs. 

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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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