- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By Jaclyn Jaeger2016-04-19T16:00:00
The Department of Justice has churned out a brief, but valuable, piece of guidance setting forth the details of a one-year FCPA enforcement pilot program, providing companies with much needed and long-awaited transparency into how the Criminal Division’s Fraud Section measures and credits voluntary self-disclosure and cooperation in FCPA investigations. ...
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2017-12-04T08:45:00Z By Jaclyn Jaeger
The Justice Department just announced its new FCPA Corporate Enforcement Policy. How different is it from the FCPA Pilot Program? And how will it change self-reporting misconduct?
2017-09-06T08:45:00Z By Jaclyn Jaeger
As the number of FCPA declinations is up, all indicators point to a general desire on the part of the DoJ and SEC to clear out old cases and re-evaluate which ones to pursue.
2017-07-11T12:45:00Z By Tom Fox
The FCPA Pilot Program declinations we have seen so far in 2017 both make substantial additions to the precedent for how to avoid prosecution under the FCPA.
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