In multiple recent cases, it seems the DOJ has softened its approach on charging self-disclosing companies for FCPA crimes involving aggravated circumstances. Bass, Berry & Sims’ Lindsey Fetzer, Thad McBride and Abby Yi discuss the implications. The U.S. Foreign Corrupt Practices Act (FCPA) does not mandate self-disclosure of potential violations. However, when determining whether to charge a corporation and how to resolve...
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