Foreign Corrupt Practices Act

Criminal Law & Procedure Practice Group Teleforum

January 28, 2018

Partner George J. Terwilliger spoke during this teleforum, hosted by The Federalist Society, regarding Deputy Attorney General Rod Rosenstein's announcement on November 29 that the Department of Justice Foreign Corrupt Practices Act “Pilot Program,” which was introduced in 2016, will be made permanent.

Topics included:

  • The disclosure dilemma and how the policy affects it
  • The fine print to consider before rushing into disclosure
  • How FCPA prosecutors may define “repeat offenders,” thereby disqualifying a company from voluntary disclosure benefits
  • The implications of a policy encouraging public pronouncements of wrong doing based on a declination of uncharged and unproved conduct

Download the discussion here.

For more information please visit the event's website.

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