Global Investigations Review
James Koukios spoke to Global Investigations Review about the U.S. Department of Justice’s (DOJ) corporate enforcement policy (CEP), an initiative through which the DOJ promises to publicly decline to prosecute a company if it self-reports potential wrongdoing, fully cooperates, and remediates Foreign Corrupt Practices Act violations, and why the number of companies receiving such a deal has slowed recently.
According to James, companies might shy away from hoping to secure a declination under the policy out of concern that the action will be public, and essentially brand them as having paid bribes. “Prior to the policy, there was the possibility that you could self-report and come out with a purely good result, but that’s mostly gone now.”
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