Earning Cooperation Credit Under the Fraud Section’s FCPA Pilot Program (Part Three of Three)

The main purpose of the Fraud Section’s FCPA pilot program appears to be to encourage companies to step forward and self-report when they learn of a possible violation. Companies that do so will be rewarded – but only if they cooperate with the DOJ fully. Encouraging companies to cooperate in investigations has been an underlying theme of the government’s messaging for years, but exactly what constitutes such full cooperation has never been laid out as clearly as it is in the FCPA Unit Guidance. However, several questions remain for companies considering cooperation. This final article in the Anti-Corruption Report’s series taking a deep look at the new pilot program addresses these areas of ambiguity and how they might influence a company’s willingness to cooperate. See previously “Going Deep on the Fraud Section’s FCPA Pilot Program (Part One of Three)” (Apr. 20, 2016); “How Will the Fraud Section’s Pilot Program Change Voluntary Self-Reporting? (Part Two of Three)” (May 4, 2016).

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