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).