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”)...