The Department of Justice’s Pilot Program awards credit and even a pass to companies that go the extra mile after finding evidence of corruption
By Thomas Fox
September 30, 2016
This year is sure to be one for the books for Foreign Corrupt Practices Act (FCPA) enforcement. By the end of June, there were more FCPA enforcement actions in 2016 than in all of 2015, and it doesn't appear that things will be slowing down anytime soon. The Fed's aggressive campaign against bribery and corruption rolls on.
Yet this surge in FCPA cases isn't even the most significant development in corruption enforcement so far this year. The single most important development is the announcement of the Justice Department's Pilot Program for FCPA enforcement, which provides some relief for companies that meet high standards for cooperating with regulators during investigations.