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).
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.
The private equity industry is facing increased scrutiny by the U.S. Government for potential violations of the Foreign Corrupt Practices Act (“FCPA”).
On June 7, the Securities and Exchange Commission (SEC) announced two non-prosecution agreements (NPAs) following a pair of investigations into alleged violations of the Foreign Corrupt Practices Act (FCPA).
On April 5, 2016, the U.S. Department of Justice announced a significant increase in its efforts to enforce the Foreign Corrupt Practices Act (FCPA).
DOJ Attempts to Encourage Corporate Self-Disclosures with the Announcement of a One-Year FCPA Pilot Program
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.
On April 5, 2016, the Fraud Section of the Criminal Division of the Department of Justice (“DOJ”) released an Enforcement Plan and Guidance (the “Plan”) regarding the Foreign Corrupt Practices Act (“FCPA”).
US Department of Justice Launches Pilot Program to Encourage Self-Reporting, Cooperation and Remediation of FCPA Violations
Last week the US Department of Justice (DOJ) announced the implementation of a pilot program under the US Foreign Corrupt Practices Act (FCPA).
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.