On Wednesday, November 29, 2017, United States Deputy Attorney General Rod J. Rosenstein announced a new Justice Department FCPA Corporate Enforcement Policy. The policy is intended to improve upon and make permanent the FCPA Pilot Program, that was announced on April 5, 2016, to enable DOJ to efficiently identify and punish criminal conduct and to provide greater certainty for companies considering whether to disclose voluntarily a potential FCPA violation to DOJ. Unlike prior guidance announced through memoranda from the assistant attorney general, the FCPA Corporate Enforcement Policy will be incorporated into the United States Attorneys’ Manual.
