The Justice Department’s FCPA enforcement program is expected to undergo a significant change in policy focus. Building on the recent adoption of the Yates Memorandum, DOJ has hired a new compliance counsel to review and evaluate FCPA compliance programs, and is modifying its corporate prosecution focus. Recent press reports have suggested that DOJ is considering offering companies leniency in exchange for full cooperation and disclosure of FCPA violations so long as the company cooperates fully in the prosecution of culpable individuals and the company maintains an effective anti-corruption compliance program. Such a change in prosecution strategy could have a significant impact on corporate liability for FCPA violations as well as corporate compliance programs.
Join Tom Fox, Principal of Advanced Compliance Solutions, and Michael Volkov, CEO of The Volkov Law Group, as they conduct a joint webinar to discuss these significant developments.
source