DOJ Introduces Self-reporting FCPA Pilot Program
In April, the U.S. Department of Justice (DOJ) introduced a one-year pilot program that would allow companies that voluntarily self-disclose potential violations of the Foreign Corrupt Practices Act (FCPA) to reduce sentencing fines by up to 50 percent.
The mitigation credit is reserved for companies that not only cooperate and remidiate, but voluntarily self-disclose the conduct. Companies that do will likely face a reduced sentencing fine and will generally not be required the appointment of a monitor.
The move comes as DOJ is enhancing the capabilities of its Criminal Division’s Fraud Section through the addition of 10 prosecutors to its FCPA unit.
Wiley Rein is hosting a webinar focused on FCPA enforcement priorities of 2016, including DOJ’s policy statements on the voluntary disclosure of FCPA violations and the implications of the Yates Memo.