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Edward Heath, left, and Dan Brody of the government enforcement and internal investigations team at Robinson & Cole. Courtesy photos

The Foreign Corrupt Practices Act continues to be a major enforcement priority for the U.S. Department of Justice and the U.S. Securities and Exchange Commission. As a result, the FCPA remains a significant focus of internal compliance efforts for U.S. companies that do business internationally.

Decisions by corporate boards, senior executives and in-house counsel about how best to investigate suspected international corruption by employees, as well as whether to disclose that kind of illegal conduct to the federal government, are often complicated by the fact that the language of the FCPA can be challenging to apply to particular circumstances with reasonable certainty, even though the DOJ has provided FCPA guidance in recent years. Acknowledging that its previous guidance has been less than clear at times, the DOJ issued public commentary on July 25 that is intended to provide enhanced predictability regarding how the government will exercise its broad prosecutorial discretion as to FCPA violations, particularly when companies “do the right thing” and self-report those violations to the DOJ. The commentary was issued as remarks by Deputy Assistant Attorney General Matthew S. Miner in connection with a global anti-corruption conference. Miner oversees the DOJ’s Fraud Section, which includes its FCPA unit.

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