Earlier this spring, the Department of Justice (DoJ) announced a pilot program for enforcing the Foreign Corrupt Practices Act (FCPA). The program credits companies for self-reporting FCPA related misconduct and is set to run for one year, at which time the results and effectiveness will be reviewed for modification and/or extension. According to the memorandum, companies that report early, cooperate and remediate are eligible for a 50% reduction off the bottom end of the Sentencing Guidelines fine range.
Enforcement of FCPA violations also falls under the purview of the SEC. Recent joint efforts by these two agencies have further enhanced the reporting guidelines and reflect a continued focus on FCPA related enforcement.