The FCPA Blog | By: Richard L. Cassin | December 22, 2017:
The DOJ’s FCPA Pilot Program — giving companies declinations or reduced penalties if they self disclose, cooperate, and disgorge profits — has now been enshrined in the U.S. Attorneys’ Manual. It’s a permanent guideline for prosecutors.
What it means for companies is more certainty. If they discover potential or actual FCPA violations, they can make better decisions about how and when to deal with the DOJ.
Beyond that, there’s more reason than ever for companies to have strong compliance programs. As George Terwilliger said in a post for the FCPA Blog,
“…to benefit from the policy the company will have to demonstrate that its compliance commitment is real and its compliance program meets standards articulated by the government, even if scaled to the size and complexity of the business entity employing it.”
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