Justice Modifies Foreign Bribery Enforcement Guidelines

James Koukios spoke to Bloomberg Law about changes to the Department of Justice’s (DOJ) procedures for offering reduced penalties when companies come clean about violations of the Foreign Corrupt Practices Act.

The changes show DOJ leadership is making good on its stated commitment to continuously assess and refine the enforcement policy, James said. “They’re actually hearing feedback – probably from both their own prosecutors and from the business community – and making those refinements to try to make the guidance more clear.” The updated language mostly reflects lessons learned in practice, “where they saw that there were some ambiguities in some of their terms.”

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