Bloomberg Law
Nov. 21, 2019, 10:55 PM

Justice Modifies Foreign Bribery Enforcement Guidelines

Jacob Rund
Jacob Rund

The Justice Department is adding new detail to its procedures for offering reduced penalties when companies come clean about violations of the Foreign Corrupt Practices Act.

“Clarifying changes” made to the DOJ’s FCPA corporate enforcement policy, released Nov. 20, update language concerning the information companies are expected to hand over when seeking leniency. The policy establishes the factors prosecutors consider in determining how much credit is offered for self-disclosures of foreign bribery.

If a company voluntarily reports misconduct under the FCPA, fully cooperates with the DOJ, and “timely and appropriately” undertakes remediation, there is a presumption in most cases that ...

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