The DOJ’s FCPA Corporate Enforcement Policy One Year Later

Last year at the American Conference Institute’s International Conference on the Foreign Corrupt Practices Act, Deputy Attorney General Rod Rosenstein announced the DOJ’s FCPA Corporate Enforcement Policy. This year at the conference, government officials reflected on the success of the Policy and provided some additional information on how it will be enforced. In particular, they discussed the controversial language in the Policy with regard to the retention of business records and disappearing messaging apps. We spoke to experts in the field to get their take on the government speakers’ comments. See our three-part series on the DOJ’s FCPA Corporate Enforcement Policy: “What’s New and What’s Not” (Jan. 10, 2018); “How Important Is the Presumption of Declination?” (Jan. 24, 2018); and “Cooperation and Compliance Expectations” (Feb. 7, 2018).

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