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Anti-Corruption

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On April 30, 2019, the Assistant Attorney General for the Department of Justice’s Criminal Division, Brian Benczkowski, announced the publication of an updated version of the Department’s Guidance Document on Evaluation of Corporate Compliance Programs (the “Revised Evaluation Guidance”). This is an update to the original version of the Department’s…

The CGU – a law enforcement entity – has given greater clarity on how each criteria provided by the law will be taken into consideration in the calculation of fines imposed on companies involved in punishable acts of corruption. Providing more detail on how the different criteria should be taken…

Amendments to FCPA Corporate Enforcement Policy In March 12, 2019, the US Department of Justice (DOJ) modified the FCPA Corporate Enforcement Policy (the “Policy”). This Policy credits corporations that voluntarily self-disclose, provide full cooperation, and demonstrate timely and appropriate remediation in FCPA matters with a presumption of declination absent aggravating…