Posts Tagged ‘rosenstein’

DOJ Expands FCPA Pilot Program

fcpa

The Justice Department is going to expand the benefits of the FCPA Pilot Program and make those benefits permanent policy, in a sweeping gesture to entice more corporations to confess possible FCPA violations and then cooperate in investigating them. Most important detail: from now on, if your company discloses an FCPA violation and meets the…

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Future of the ‘Effectiveness Questions’

The other day a compliance officer asked me an interesting question: What’s going to happen to the Justice Department’s guidelines for evaluating the effectiveness of compliance programs? After all, the Trump Administration talks all the time about streamlining regulation. Deputy attorney general Rod Rosenstein has given a series of speeches this fall promising reviews of…

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Rosenstein Talks Yates Memo, Says Diddly

fcpa

Don’t look now, but the compliance Internet is all a-Twitter today because Deputy Attorney General Rod Rosenstein said in a public forum that maybe, sometime soon, the Justice Department might change its views of corporate cooperation under the Yates Memo— or then again, maybe not. Who knows, really. To remind everyone, the Yates Memo is…

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