New FCPA Corporate Enforcement Policy May Be Repositioning the Trigger in Voluntary Disclosure Analysis

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On November 29, 2017, Deputy Attorney General Rod Rosenstein revealed the implementation of the FCPA Corporate Enforcement Policy ("Enforcement Policy"), which endeavours to supplemental reassure voluntary disclosure of FCPA violations by companies. The Enforcement Policy attempts to elucidate certain viewpoints of the FCPA Pilot Program launched by the Fraud Section in April 2016 and removes its "pilot" status by incorporating the general framework for credit for voluntary disclosure of FCPA violations into the United States Attorney's Manual (USAM).

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