Foreign Corrupt Practices Act “Pilot Program” Still Alive and Kicking

In April 2016, the Department of Justice (DOJ) launched the foreign corrupt practices act (FCPA) Pilot Program. The program puts into effect several policies introduced in the famous “Yates Memo,” outlining guidance on voluntary self-disclosure of FCPA transgressions, investigation cooperation, individual accountability and even how cooperation  can result in non-prosecution. Despite expected regulatory rollbacks and ironically, the highly public firing of the Yates Memo author Acting US Attorney General Sally Yates, the Trump administration shows no signs of let up in FCPA enforcement or the Pilot Program.

Last month, Acting Assistant Attorney General Kenneth A. Blanco announced that the DOJ will evaluate the Pilot Program for extension and any revisions when it expires in April 2017. In the meantime, Blanco advises that the program remains in full force and effect.  Here’s an article to learn more about how the Pilot Program works.


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