White Collar Roundup - May 2016

The DOJ announced a one-year pilot program to handsomely reward companies that self-report violations of the Foreign Corrupt Practices Act. The program is detailed in "The Fraud Section's Foreign Corrupt Practices Act Enforcement Plan and Guidance." In announcing the program, Assistant Attorney General Leslie R. Caldwell described the increased resources and personnel at the DOJ tasked with investigating and prosecuting FCPA violations, which increase "should send a powerful message that FCPA violations that might have gone uncovered in the past are now more likely to come to light." The pilot program "is designed to motivate companies to voluntarily self-disclose FCPA-related misconduct, fully cooperate with the Fraud Section, and, where appropriate, remediate flaws in their controls and compliance programs." Caldwell also made clear that any disclosure would make the company eligible for a "reduction of up to 50 percent below the low end of the applicable U.S.