European Response To DOJ's Changes In FCPA Enforcement

In recent months, the U.S. Department of Justice (DOJ) has hit "pause" on enforcement of the Foreign Corrupt Practices Act (FCPA) and reoriented its other enforcement priorities away from investigating and prosecuting corporate bribery of U.S. companies.

But these changes should not be mistaken for a global retreat from anti-corruption efforts or a shift in international or even U.S. regulators' views on the need for robust internal controls and compliance programs. To the contrary, in May the DOJ issued new policies incentivizing companies to report, among other criminal violations, foreign corruption. In addition, three major developments in Europe underscore the continuing international regulatory interest in combating bribery and corruption and reinforce the need for strong internal controls and compliance programs: (1) the creation of an International Anti-Corruption Prosecutorial Taskforce (IATP), (2) the U.K's enactment of a new criminal offense, the Failure