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FCPA Corporate Enforcement Policy Update: DOJ Introduces New Compliance Requirements for Companies Using Instant Messaging Platforms
On March 12, 2019, the United States Department of Justice (the “DOJ”) revised key provisions of the FCPA Corporate Enforcement Policy (the “Policy”). The revisions formalize several of the DOJ’s remarks and announcements since the Policy was adopted, and relaxed and clarified several criteria for self-disclosure, cooperation, and remediation.