The New FCPA Cooperation Plan

On April 5, 2016, the DOJ issued an Enforcement and Guidance Plan concerning the 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.

11 minute read September 01, 2016 at 11:28 AM
By
Brett W. Johnson and Jeffrey Scudder
The New FCPA Cooperation Plan

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).

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