Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Tag Archives: DOJ FCPA Pilot Program

Enforcement and Prosecution Policy and Trends

U.S. Supreme Court Indirectly Limits Important Component of DOJ’s FCPA Pilot Program

On June 5, 2017, the U.S. Supreme Court unanimously held in Kokesh v. Securities and Exchange Commission, No. 16-529, that the SEC may not reach beyond the general five year statute of limitations period in order to obtain “ill-gotten gains,” a remedy known as disgorgement. Although the case did not involve a Foreign Corrupt Practices… Continue Reading
Anti-Bribery and Corruption, Enforcement and Prosecution Policy and Trends

Last Four Months of DOJ’s FCPA Pilot Program Could Provide Important Signals

Last April, the Criminal Division of the U.S. Department of Justice launched a one-year pilot program in the Fraud Section’s Foreign Corrupt Practices Act (“FCPA”) Unit.  The pilot program, self-described as “building” on the Yates memorandum, provides structured incentives for companies to self-disclose, cooperate, and remediate with respect to FCPA violations.  The remaining four months… Continue Reading

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