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.
These allow us to recognize and count the number of users of our website and understand how such users navigate through our website. This helps to improve how our website works, for example, by ensuring that users can find what they are looking for easily. These cookies are session cookies which are erased when you close your browser.
These improve the functional performance of our website and make it easier for you to use. For example, cookies are used to remember that you have previously visited the website and asked to remain logged into it. These cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our website. You can delete these cookies via your browser settings.
These cookies record your visit to our website, the pages you have visited and the links you have followed to recognize you as a previous visitor and to track your activity on the website and other websites you visit. These cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our Website. You can delete these cookies via your browser settings.
These are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas. These cookies are session cookies that are erased considering the expiration duration set in the last column [Expiry] of the table below.