The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu The leading online blog in the fields of corporate governance and financial regulation. Thu, 20 May 2021 13:55:45 +0000 en-US hourly 1 https://wordpress.org/?v=5.7.1 Revised FCPA Corporate Enforcement Policy https://corpgov.law.harvard.edu/2017/12/16/revised-fcpa-corporate-enforcement-policy/ https://corpgov.law.harvard.edu/2017/12/16/revised-fcpa-corporate-enforcement-policy/#respond Sat, 16 Dec 2017 14:20:00 +0000 https://corpgov.law.harvard.edu/?p=103539?d=20171218093831EST Posted by Gary DiBianco, Jocelyn E. Strauber, and Daniel B. Weinstein, Skadden, Arps, Slate, Meagher and Flom LLP, on Saturday, December 16, 2017
Editor's Note: Gary DiBianco and Jocelyn E. Strauber are partners and Daniel B. Weinstein is an associate at Skadden, Arps, Slate, Meagher and Flom LLP. This post is based on a Skadden publication by the above authors, Mitchell S. Ettinger, Warren Feldman, Keith D. Krakaur, David Meister, and Warren T. Allen II.

In a speech [November 29, 2017] at the 34th International Conference on the Foreign Corrupt Practices Act, U.S. Deputy Attorney General Rod Rosenstein announced the Department of Justice’s (DOJ) revised Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy. He explained that the revised policy is based on the DOJ’s determination that the FCPA Pilot Program in place for the last 18 months was a “step forward” in fighting corporate crime but also could be improved in certain respects. The revised policy, while similar in many respects to the Pilot Program, seems designed to further encourage voluntary disclosures of FCPA-related misconduct, including by conferring a presumption in favor of a declination for those companies that meet the revised policy’s requirements.

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