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.
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DOJ Declinations under FCPA Corporate Enforcement Policy
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