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DOJ’s New FCPA Guidelines: The Next Chapter in US Foreign Corruption Enforcement
DLA Piper – The Department of Justice has released long-awaited guidance (FCPA regarding its approach to enforcement of the Foreign Corrupt Practices Act (FCPA) following the Executive Order pausing FCPA enforcement. The Guidelines emphasize a prosecutorial focus on protecting US interests, significant criminal conduct rather than routine business practices, and consideration of the impact on companies and individuals targeted by an enforcement action. They also provide a non-exhaustive list of factors to evaluate when determining whether to proceed with an investigation or enforcement action.