Tagged: root cause analysis

Five Key Takeaways from DOJ’s New FCPA Corporate Enforcement Policy

Five Key Takeaways from DOJ’s New FCPA Corporate Enforcement Policy

In a significant FCPA enforcement development, DOJ’s Deputy Attorney General (“DAG”) Rod Rosenstein announced the implementation of a new FCPA Corporate Enforcement Policy last week. (Here).  The announcement was not a surprise based on earlier statements made by DAG Rosenstein. Before outlining the specific five takeaways, there are a few issues surrounding the release of the new policy that require some comment. DAG Rosenstein implemented...