The Department of Justice’s policy regarding corporate enforcement of the Foreign Corrupt Practices Act has evolved in meaningful ways since 2016. While the policy developments themselves have been frequently discussed, publicly available declination letters from 2018 through the present provide valuable, concrete examples of how the policy is actually being implemented. This article provides an examination of the facts surrounding declinations under the current policy and highlights key trends and takeaways from the DOJ’s six most recent declination letters.
Regulations, Compliance, & Enforcement
Trending Now
DoD Proposes Major FOCI Reporting Requirements • (Not) All’s Weld That Ends Weld: Duty Evasion Scheme Ends in Historic $549.5M FCA Settlement • From Fixable to Fineable: ICE’s Quiet Overhaul of I-9 Violation Classifications • Two Running Buddies Discuss 6000 Federal Contractor Audits • How America Lost Its Most Important Defense Tech Habit
DOJ Declinations under FCPA Corporate Enforcement Policy
MDart10 | Shutterstock
Track False Claims Act cases, audit trends, and compliance best practices with our Compliance & Enforcement newsletter, delivering up-to-the-minute intelligence Monday–Saturday — Subscribe here.