How Significant Is the DOJ’s New Directive on Coordination?

In what he described as “another step towards greater transparency and consistency in corporate enforcement,” Deputy Attorney General Rod Rosenstein recently announced a new DOJ policy designed to reduce “disproportionate enforcement of corruption laws by multiple authorities.” When bringing corporate cases, “the Department,” Rosenstein stated in a memo distributing the policy, “should consider the totality of fines, penalties, and/or forfeiture imposed by all Department components as well as other law enforcement agencies and regulators in an effort to achieve an equitable result.” The Anti-Corruption Report spoke with former DOJ prosecutors about the impact the new policy will have on anti-corruption enforcement. 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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