FCPA Compliance Report: Recent DOJ Policy Announcements | Thomas Fox – Compliance Evangelist
They take a deep dive into Deputy Attorney General Todd Blanche’s memo on See more +
They take a deep dive into Deputy Attorney General Todd Blanche’s memo on Investigations and Enforcement of the FCPA, reviewing the stated main goals of the DOJ and how prosecutors are supposed to achieve these goals. They also consider three directives to prosecutors: focus on cases involving individual misconduct, proceed expeditiously, and consider the collateral consequences. They also examine the White Collar Plan and CEP and ask if we have shifted from a presumption of declination to a more tangible framework and conclude by reviewing what compliance professionals need to consider and investigate now.
Key highlights include:
• How does the principle of “not attribute[ing] nonspecific malfeasance to corporate structures” impact potential prosecutions of companies and individuals?
• And how do these priorities jive with other DOJ priorities, such as prosecuting cartels/transnational criminal organizations?
• What does it mean for companies that the DOJ is prioritizing “serious misconduct”?
• What are the implications of the DOJ’s stated intent to avoid penalizing “routine business practices in other nations”?
• Do you see this as a shift in focus for the DOJ to non-US companies?
• Other DOJ Priorities & Announcements
• Policy Shifts and Clarifications
• Looking Ahead: What’s on the Horizon See less –
