In the News
The new FCPA enforcement circle is now complete (Compliance Week)
Compliance Week, July 19, 2016
The new FCPA enforcement circle is now complete
“It all began with the Yates Memo, which mandated that companies self-disclose and turn over information on individuals who may have been complicit in conduct that violated the FCPA. While many commentators placed new emphasis on individuals, most missed the additional key factor of early self-disclosure. The result, noted U.S. Deputy Attorney General Sally Yates in a May speech at a white-collar crime conference hosted by the New York City Bar Association, is that companies are self-disclosing even before their investigations are complete to present factual evidence to the Justice Department.”
