DOJ’s Guidance Shows That Compliance Programs Still Matter

Critical comments of the FCPA by President Trump, coupled with a general policy position of lessening regulatory oversight of U.S. companies, have caused speculation as to whether the new administration will curtail FCPA enforcement. Recently, the DOJ Fraud Section quietly released this administration’s first guidance setting out its position on the contours of an effective corporate compliance program. In a guest article, Paul Hastings partners Tara Giunta and Palmina Fava, and their associate Brian Wilmot, explain that this guidance does not signal any easing of enforcement – rather, the Fraud Section is signaling an incisive review of companies and their compliance programs, functions, resources and effectiveness. See “Top FCPA Officials Encourage Strong Compliance Programs and Remediation, the Defense Bar Responds” (Dec. 21, 2016).

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