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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.

August 13, 2020
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Insight

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…

March 20, 2019
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Insight

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…

March 14, 2019
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Insight

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…

March 7, 2019