Updates to the Corporate Enforcement Policy Attempt to Address Company Concerns

The DOJ’s recent revision of its FCPA Corporate Enforcement Policy appears to have been motivated, at least in part, by public opinion that the government was overreaching with regard to document retention and de-confliction. The Anti-Corruption Report spoke with former Fraud Section prosecutors to hear their take on what motivated the revisions, how big the changes really are and what impact they are likely to have on internal investigations and cooperation. See “The DOJ’s FCPA Corporate Enforcement Policy One Year Later” (Dec. 12, 2018).

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