Lawyers
Litigation partner Mark Mendelsohn and counsel Ben Klein discuss the DOJ’s new guidelines on enforcement of the Foreign Corrupt Practices Act (FCPA) in an article in Law.com, “Press Play: DOJ Ends FCPA Enforcement Pause, Offers New Guidelines for Companies,” published on June 27. Mark and Ben assess what the new approach will mean for companies and suggest that they may benefit from more “breathing room” from federal prosecutors deciding whether to initiate investigations or pursue prosecutions. They note that the new guidelines make clear that FCPA investigations and enforcement actions must serve U.S. interests and safeguard opportunities for US companies. While Mark and Ben advise companies against any rollback of their FCPA compliance programs and predict an increase in scrutiny for companies operating in sectors related to national security, they note that “the guidelines suggest that the DOJ will be less inclined to prosecute companies for conduct considered to be ‘routine business practices.”
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