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ARTICLE · 21 DECEMBER 2023

Foreign Corrupt Practices Act Update: Considerations Around Voluntary Disclosures

Bass, Berry & Sims PLC
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In September 2022, Deputy Attorney General Lisa Monaco outlined the Department of Justice (DOJ) approach to enforcing corporate misconduct and directed agencies to review existing voluntary self-disclosure policies or, if none exist, draft new ones.

United StatesCriminal Law
Thaddeus R. McBride
Thaddeus R. McBride

In September 2022, Deputy Attorney General Lisa Monaco outlined the Department of Justice (DOJ) approach to enforcing corporate misconduct and directed agencies to review existing voluntary self-disclosure policies or, if none exist, draft new ones.

Two recently announced Foreign Corrupt Practices Act (FCPA) settlements involving reinsurance companies demonstrate what happens when the rubber hits the road.

Jardine Lloyd Thompson Group Holdings Ltd. Receives Declination

In March 2022, the DOJ issued a declination letter stating that it would be declining to prosecute Jardine Lloyd Thompson Group Holdings Ltd. (JLT) notwithstanding violations of the anti-bribery provisions of the FCPA. According to the DOJ, between 2014 and 2016, JLT employees and agents used a third-party intermediary to pay over $3 million in bribes to Ecuadorian officials to obtain business with Seguros Sucre, an Ecuadorian state-owned surety company.

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