Recent statements by top Department of Justice officials suggest prosecutors may consult the FCPA Corporate Enforcement Policy for guidance on assessing whether a company’s self-reporting and remediation measures may justify declination for matters other than FCPA enforcement.
During a presentation at the American Bar Association’s White Collar Conference on March 1, John Cronan, acting assistant attorney general for DOJ’s Criminal Division, and Benjamin Singer, chief of the Fraud Section’s Securities and Financial Fraud Unit, noted that the department intends to “reward self-disclosure, full cooperation, and timely and appropriate remediation” by declining to bring cases against companies investigated for criminal violations other than the FCPA.
Read the full post from Morgan, Lewis & Bockius LLP via the National Law Review
