Notably, the DOJ is doubling down on encouraging voluntary disclosure. Under the new guidelines, companies that self-report, cooperate, and remediate in cases of FCPA violations will receive a formal declination, except in truly “aggravating” circumstances. This appears to signal that the agency will closely scrutinize any internal recommendation not to issue a declination in those cases, meaning the path to avoiding prosecution is clearer than ever for companies that respond promptly and cooperate fully.
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