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DOJ’s Quiet Changes to the FCPA Corporate Enforcement Policy Likely to Have a Significant Impact on Corporate Investigations

Firm Memoranda
As the annual ABA White Collar Crime Conference wrapped up in New Orleans last Friday night, Department of Justice (DOJ) released the latest updates to its FCPA Corporate Enforcement Policy. The key changes to the policy include new guidance regarding: (1) mergers and acquisitions and legacy liability as a result of misconduct prior to the acquisition; (2) DOJ’s interactions with company counsel and requests that company counsel refrain from taking investigative steps; and (3) the scope of disclosure and remediation required in order to be eligible for a declination under the policy. Although the DOJ chose to release the amendments with little fanfare, corporate executives, boards of directors, special committee members and practitioners alike will feel the effect immediately.
 
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If you have any questions about the issues addressed in this memorandum, or if you would like a copy of any of the materials mentioned in it, please do not hesitate to reach out to:
 
Partner
Co-Chair, Investigations, Government Enforcement & White Collar Criminal Defense Practice and Crisis Law & Strategy Practice
Email: sandramoser@quinnemanuel.com
Phone: +1 202-538-8333

Daniel Koffmann
Associate
Email: danielkoffmann@quinnemanuel.com
Phone: +1 212-849-7617