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A recurring question of general counsel and chief compliance officers is whether their proactive investments in compliance programs, voluntary self-disclosure of issues, and cooperation will be meaningfully rewarded.
Last week, the Department of Justice (“DOJ” or “Department”) made a series of changes to the 2017 FCPA Corporate Enforcement Policy (“Policy”) contained in the Justice Manual (until last year, known…
On March 7 and 8, 2019, Deputy Attorney General Rod Rosenstein and Assistant Attorney General Brian Benczkowski delivered separate speeches on developments in FCPA enforcement, highlighting that DOJ…
In the first FCPA enforcement action of the 2019 season, DOJ issued a particularly lenient declination to Cognizant Technology Solutions Corporation, but required additional disgorgement beyond what…