DOJ Enforcers Tout Transparency, the Defense Bar Responds

While the DOJ sometimes makes big announcements at the American Conference Institute’s Annual International Conference on the Foreign Corrupt Practices Act held in Oxon, Maryland, “there was not much new this year,” Tarek Helou, a recent FCPA Unit alum and partner at Wilson Sonsini, observed. Major new developments may have been in short supply, but speakers from the DOJ did seek to clarify recent policy initiatives and highlight the Department’s push to increase transparency, predictability and, ultimately, trust in how companies will be treated if they self-report issues. “As we have seen with the recent policy initiatives, the conference continued to illustrate DOJ’s push toward more transparency in its operations, so that the business community has a better understanding of the government’s expectations,” Ephraim (Fry) Wernick, another recent DOJ FCPA Unit alum and partner at Vinson & Elkins, commented. The Anti-Corruption Report attended the conference and spoke with members of the defense bar to analyze what was said. See “New DOJ Guidance Offers a Gentler Standard on Inability-to-Pay Claims” (Oct. 30, 2019).

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