What's new about the DOJ's new FCPA corporate enforcement policy?

FCPA practitioners welcomed Rod Rosenstein’s announcement that the Department of Justice has made the FCPA Pilot Program permanent, and incorporated it into the U.S. Attorneys’ Manual. The audience “noticeably lightened up” at the Deputy AG’s news. Now that we’ve had an opportunity to digest the newly-styled FCPA Corporate Enforcement Policy, let’s examine some of the key differences from the original 2016 FCPA Pilot Program. 

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