Global Investigations Review
New guidance on how the DOJ approaches companies’ inability-to-pay claims coupled with a rise in multilateral enforcement actions could lead to more businesses claiming they are too poor to pay proposed fines. James Koukios, Global Co-Head of Morrison & Foerster’s FCPA + Anti-Corruption Practice, offers his thoughts on the guidance. Speaking from his extensive DOJ experience, James comments on the frequency of inability-to-pay claims and details how he thinks the revised approach will affect number of companies filing such claims in the future.
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