Announcement of Policy Revisions Reflects a More Practical, Flexible Enforcement Approach The US Justice Department has adjusted its approach to holding individuals, and not only corporations, responsible for improper conduct. In remarks at the ACI’s FCPA conference on November 29, Deputy Attorney General Rod Rosenstein softened the DOJ’s formal policy…
President Trump signed an executive order calling for increased monitoring and enforcement of laws that require — or express a preference for — domestic goods, services, and labor. Trump’s order requires more rigorous enforcement of “Buy American” laws that require agencies and government contractors to procure goods, products or materials that are produced in the United States.
Baker McKenzie’s Aerospace & Defense Compliance Bullet highlights significant compliance developments relevant to companies in the Aerospace & Defense industry and offer practical guidance with respect to business operations in various regions.
The DOJ’s Foreign Corrupt Practices Act Pilot Program reached its six-month anniversary on October 5, 2016. Since the program began, the DOJ has announced multiple corporate FCPA resolutions.
Harris’ declination from the SEC represents the first time in a “pure” FCPA investigation that a multinational corporation has avoided prosecution entirely while one of its former employees was sanctioned for FCPA violations that created clear potential FCPA liability for the company.