One of the biggest complaints heard from clients is that it's difficult to calculate the potential benefits of self-reporting. In response, the DoJ launched a pilot program to encourage corporate compliance through an incentive program offering up to 50 percent off of fines and minimum sentencing guidelines for companies that self-report FCPA violations, cooperate with investigators and take measures to prevent future fraud.
There is an increased focus on corporate crime and international corruption since the creation of three dedicated FCPA squads, and a memo stressing the importance of holding individuals accountable in corporate prosecutions. In this article, Scott Moritz discusses what the DoJ is looking for upon responding to an incident.