Tagged: FCPA Guidance

FCPA Enforcement and Credit for an Effective Compliance Program

The Justice Department has touted its efforts to bring greater transparency to FCPA enforcement. There is no question that in the last five years the Justice Department has moved the needle – the FCPA Guidance issued in 2012; the release of the April 5, 2016 Pilot Program; the Evaluation of Corporate Compliance Programs issued in February 2017; the release of letters confirming declinations awarded to...

Transparency in FCPA Enforcement

We all value transparency as a general concept, especially when it comes to the government. In a real macro perspective, we fund the government and we demand that our government operate efficiently, effectively and ethically. Transparency is a fundamental requirement for all citizens to monitor and regulate our government. When it comes to our criminal justice system, or the enforcement of our laws, we expect...

Compliance 2.0: DOJ Pushes the Compliance Agenda

The FCPA Paparazzi have a thick head and a stubborn chin. They just do not understand the significance of Compliance 2.0 to corporate governance and they blindly adhere to simplistic, yet unexplained, solutions to complex problems – kind of sounds like a presidential candidate we all know. Without getting into politics, which I avoid here on this blog, DOJ’s recent FCPA guidance on voluntary, disclosure,...