New US Department of Justice Foreign Corrupt Practices Act Enforcement Plan Creates "Pilot Program" to Encourage Voluntary Disclosure

April 19, 2016

The U.S. Department of Justice (“DOJ”) released a memorandum (the “FCPA Enforcement Memorandum”) on April 5, 2016 detailing a new enforcement plan for Foreign Corrupt Practices Act (“FCPA”) investigations. The DOJ announced that it will significantly increase resources devoted to the FCPA (adding ten new prosecutors and additional investigators), will strengthen the DOJ’s coordination with international law enforcement counterparts, and implement a "pilot program" designed to encourage self-reporting. The FCPA Enforcement Memorandum also underscores the DOJ’s increased focus on prosecution of individuals, as detailed in the September 2015 Yates Memorandum on Individual Accountability (The "Yates Memorandum"). For U.S. companies doing business overseas, the message from the DOJ’s latest pronouncement is just how critical a well-executed, properly tailored internal investigation can be and how difficult the decision to self-report remains.

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