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.
- 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.