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The DOJ Fraud Section’s recently released FCPA Enforcement Plan and Guidance outlines a novel one-year pilot program for corporate self-reporting and cooperation, with specific fine reduction incentives.
A predominant theme to the DOJ Plan’s overall effective compliance approach is the commercial sector mantra (also used by the infamous 1930’s bank robber Willy Sutton): go where the money is. Financial considerations are integral to the DOJ Plan’s structure and remedial expectations. Read the whole article on the FCPA Blog.
Image credit: Tony Webster, Flickr. (Image has been modified.)