DOJ Policy Developments: One Year On, What You Need To Know for Your FCPA Investigations and Compliance Program

04 Apr , 2024

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Last year, the DOJ issued new or revised policies that impact Foreign Corrupt Practices Act (FCPA) prosecutions and expectations for corporate compliance programs. These policies include a new Safe Harbor Policy for voluntary self-disclosures made in connection with mergers and acquisitions, a three-year Compensation Incentives and Clawbacks Pilot Program, updated guidance on the Evaluation of Corporate Compliance Programs, and a Revised Memorandum on Selection of Monitors in Criminal Division Matters. 

In this presentation, we’ll discuss some of the most important takeaways for companies to consider as they investigate potential FCPA violations, consider potential disclosure or cooperation with authorities, and review the effectiveness of their compliance programs, including: 

M&A-related safe harbor expectations, the DOJ’s policy on corporate management of personal devices and third-party apps, expectations for compensation programs (including compensation clawbacks), and cooperation standards for companies under investigation.

Provide practical ways for companies to address the changing landscape of DOJ guidance.

Discuss best practices in compliance program development.

 

To register for the upcoming live webinar, please Click Here

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