DOJ’s FCPA Corporate Enforcement Policy: Cooperation and Compliance Expectations (Part Three of Three)

Following the announcement of the DOJ’s new FCPA Corporate Enforcement Policy (the Policy) late last year, the focus was on the incentives it offered companies to self-report anti-corruption issues. The Policy, however, also contains important clarifications on what the DOJ expects from companies in terms of cooperation and compliance program remediation. In this final article in a three-part series on the DOJ’s new Policy, we look at the new guidance the DOJ has provided on de-confliction, compliance authority and document retention. See “Using the FCPA Pilot Program’s Remediation Requirements to Build a Best-in-Class Compliance Program” (May 18, 2016).

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