- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Kyle Brasseur2023-10-12T16:00:00
More corporate enforcement guidance geared to provide companies a path toward penalty reductions or declinations. Reiterated messages regarding the importance of investing in compliance. A slow year for Foreign Corrupt Practices Act (FCPA) enforcement. All these trends at the Department of Justice (DOJ) can be easily linked together as part of one larger narrative.
My guess at the result: The DOJ is gearing up for a lot of future “we warned yous.”
The realist in me finds it hard not to believe all the carrots being offered by the DOJ in the past year—greater penalty reduction thresholds, relief related to compensation clawbacks, voluntary self-disclosure incentives—are part of a strategy to strengthen the enforcement stick when companies don’t cooperate. Former Criminal Division head Kenneth Polite Jr. said as much during his keynote address at Compliance Week’s 2022 National Conference.
“Support your compliance programs now—or pay later,” Polite said.
His acting successor, Nicole Argentieri, hasn’t drifted from this stance.
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Nicole Argentieri, acting head of the Department of Justice’s Criminal Division, explained how the actions of Jardine Lloyd Thompson Group Holdings coming forward helped bring about the agency’s recent FCPA enforcements against Tysers Insurance Brokers and H.W. Wood.
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