General
Revised FCPA Guidance: Updated DOJ Policies (Part III of V)
The Justice Department has continued at a steady rate to tweak relevant policies applicable to FCPA enforcement. The Revised FCPA Guidance has incorporated these policies. FCPA Corporate Enforcement Policy and Declinations (pp. 51-54) The FCPA Corporate Enforcement Policy is quickly becoming “a well-established” framework. DOJ has expanded it