DOJ Launches FCPA Pilot Program For Voluntary Self-Disclosure – What Does It Offer?

On April 5th, 2016, the Department of Justice ("DOJ") announced the Foreign Corrupt Practices Act Enforcement Plan and Guidance ("Guidance") which aims to ensure greater accountability for Foreign Corrupt Practices Act ("FCPA") violations and provide greater transparency for companies with regard to mitigation. The Guidance launches a pilot program that provides even further mitigation possibilities to companies which fulfill the conditions set out in the Guidance. The pilot program will be effective for a year, starting from April 5th, 2016.  

Before delving into the pilot program, the Guidance points out the two other ways the DOJ targets to increase accountability. The first of these is an increase in FCPA enforcement resources. The second is an increase in international cooperation between law enforcement authorities around the world.