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Enforcement Attorneys Examine Outcomes of FCPA Pilot Program at One Year Mark

Practices: Anti-Corruption / International Risk, Securities & Public Companies, Private Equity, Government Enforcement / White Collar Crime, Litigation, Life Sciences, Technology, Media & Telecommunications, Hedge Funds

In an article published by Law360, government enforcement partner Ryan Rohlfsen and associate Sarah Kimmer examine patterns and key takeaways from the "Foreign Corrupt Practices Act Enforcement Plan and Guidance” announced by the U.S. Department of Justice Criminal Division's Fraud Section in April 2016. The article notes that over one year, seven companies resolved self-reported misconduct, and five received the pilot program’s maximum reward —a declination. The authors also note that “further anti-corruption developments abroad will only serve to increase pressure on the DOJ to strengthen its FCPA efforts.”