The Justice Department has continued at a steady rate to tweak relevant policies applicable to FCPA enforcement. The Revised FCPA Guidance has incorporated these policies. FCPA Corporate Enforcement Policy and Declinations (pp. 51-54) The FCPA Corporate Enforcement Policy is quickly becoming “a well-established” framework. DOJ has expanded it to cover all corporate criminal resolutions except for criminal antitrust violations. The FCPA Corporate Enforcement Policy (“CEP”)...
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