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The New FCPA Cooperation Plan

By Brett W. Johnson and Jeffrey Scudder
September 01, 2016

On April 5, 2016, the U.S. Department of Justice (DOJ) issued an Enforcement and Guidance Plan (Plan) concerning the Foreign Corrupt Practices Act (FCPA). While the new Plan could be interpreted as a novel departure from past precedent, careful analysis reveals that it does little to alter or clarify how the DOJ will review cases or reward companies for significant cooperation in addressing anti-corruption global issues.

Background on the FCPA and Previous Agency Interpretations

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