White Collar Roundup (December 2017)

DOJ Further Strengthens FCPA Self-Disclosure Program

In a speech at the 34th International Conference on the Foreign Corrupt Practices Act, U.S. Deputy Attorney General Rod Rosenstein announced an updated FCPA enforcement policy to provide organizations with an incentive to voluntarily disclose organizational wrongdoing. He began by acknowledging that "it is not for the Department of Justice to say whether the FCPA reflects sound policymaking. The United States Congress made that judgment. Our mission is to detect, deter, and punish violations of the laws of the United States." He also reemphasized the DOJ's continued focus on individuals, noting, "Effective deterrence of corporate corruption requires prosecution of culpable individuals. We should not just announce large corporate fines and celebrate penalizing shareholders." Further, he lauded companies with robust compliance programs, saying, "a company with a robust compliance program can prevent corruption and