Analysis

The Evolution of DOJ’s FCPA Corporate Enforcement Policy: DOJ’s Attempt To Minimize the Fear of the Unknown

This article will summarize the evolution of the Policy and conclude with steps companies should take if they are subject to the FCPA.

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Washington, DC / USA - April 22 2019: The northern facade of the Department of Justice building in the nation's capital. Washington, D.C. / USA – April 22 2019: The northern facade of the Department of Justice building in the nation’s capital.

On Nov. 20, 2019, the U.S. Department of Justice (DOJ) amended the Foreign Corrupt Practices Act’s (FCPA) Corporate Enforcement Policy (the Policy) in an effort to provide clarity on what constitutes voluntary self-disclosure and full cooperation for companies in FCPA matters. U.S. Dep’t of Justice, U.S. Attorneys’ Manual §9-47.120 (2019) (FCPA Corp. Enfor. Policy). The recent changes to the Policy show an ongoing trend and effort by DOJ to make its guidance clear, in part, to encourage companies to make earlier disclosures. The changes also reflect a better understanding by DOJ of the practical implications of business operations and internal investigations.

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