Member Article

The United States Department of Justice launched a one-year pilot program, effective April 5, 2016, incentivizing companies to disclose facts about corporate officers, supervisors, employees, and agents involved in violations of the Foreign Corrupt Practices Act, 15 U.S.C. §§ 78dd-1, et seq. The FCPA makes it a crime for a U.S. citizen or entity, among others, to bribe a foreign official to gain a business advantage. The Program echoes the themes in the DOJ’s 2015 “Yates Memorandum,” which highlighted the DOJ’s renewed focus on individual accountability for corporate wrongdoing. Citing greater accountability for individuals and companies, the goal of the Program, according to DOJ’s Fraud Section Chief Andrew Weissmann, is to motivate “companies to voluntarily self-disclose FCPA-related misconduct, fully cooperate with the Fraud Section, and, where appropriate, remediate flaws in their controls and compliance programs.”

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