DOJ’s new approach to FCPA enforcement presents some interesting opportunities — the headlines from the DOJ FCPA Guidance Memo will bring some significant changes but at the same time some things will not change.  Here is my list of what’s new and what’s the same. 1.  Increased individual prosecutions and reduced emphasis on corporate prosecutions: The DOJ FCPA Guidance Memo prioritizes individual prosecutions and avoidance...

The Justice Department has returned to the FCPA enforcement arena — in a significant development, DOJ announced the resumption of FCPA enforcement, with a new set of enforcement guidance principles.  The new guidance is an important statement governing FCPA investigations and prosecutions. The impact of this new approach will be significant — the precise scope of this renewed focus will depend on certain legal factors,...