US DOJ applies carrot-and-stick approach to Foreign Corrupt Practices Act policy

The US Department of Justice (DOJ) has taken a carrot-and-stick approach to its corporate enforcement policy in regard to the Foreign Corrupt Practices Act (FCPA) in an effort to entice companies to self-report when in violation of the FCPA. Assistant Attorney General Kenneth A. Polite, Jr., shared the 2022 success of the Criminal Division of the DOJ in its pursuit of corrupt and criminal activities within corporations that “threaten the public safety and national security, [and] wrongfully divert money into the pockets of criminal actors” at a mid-January event at Georgetown University’s Law Center.

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