Rosenstein Announces New FCPA Corporate Enforcement Policy and Promises Ongoing Enforcement

Nearly a year into the new administration, the DOJ’s stance on the FCPA is consistent enough to dispel most speculation about lax enforcement in the Trump era. Despite the President’s stated distaste for the law, prosecutions continue and DOJ officials consistently pledge to enforce the Act, although their remarks often take on a pointedly business-friendly tone. In a speech given at ACI’s 34th Annual International Conference on the Foreign Corrupt Practices Act, Deputy Attorney General Rod Rosenstein continued that trend, promising ongoing FCPA enforcement while stressing that enforcement should create a “level playing field” that “protects citizens and honest businesses.” The highlight of his speech was the announcement of a new DOJ FCPA Corporate Enforcement Policy, which will be discussed in detail in an upcoming issue of the Anti-Corruption Report. See “From FCPA Prosecutor to Company Protector: An Insiders’ View on the Current Climate” (Nov. 15, 2017).

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