Jay Holtmeier Erin Sloane

February 08, 2018 | New York Law Journal

On Nov. 29, 2017, Deputy Attorney General Rod Rosenstein announced a new FCPA Corporate Enforcement Policy based on the 2016 FCPA Pilot Program, which first attempted to formalize the DOJ's treatment of self-disclosure, cooperation, and remediation in the FCPA enforcement context. In announcing the new Policy, Rosenstein explained the DOJ's view that the Pilot Program had been successful, significantly increasing self-disclosure rates. The Policy, however, is a somewhat mixed bag for companies struggling to decide whether to voluntarily disclose misconduct.

By Jay Holtmeier, Erin Sloane and Jeff Habenicht

8 minute read