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Ex-DOJ Criminal Chief Sees Red Flags In FCPA Pilot

October 26, 2016, Law360

Lanny Breuer participated at the FCPA Blog Conference and is quoted in a Law360 article regarding concerns raised by a requirement under a pilot Foreign Corrupt Practices Act disclosure program forcing companies to step back from conducting their own investigations. According to Breuer, the FCPA pilot program makes “an extraordinary request” by mandating that companies seeking to have the government decline to bring a corruption case must “deconflict” and halt their own internal investigations of potential violations. 

By making that request, prosecutors are preventing companies that have self-disclosed a potential FCPA violation to avoid prosecution from getting their arms around a problem as they normally would. That can pose a serious problem for management and boards who are trying to address corruption within corporate ranks on their own, Breuer said. “In general, particularly for publicly traded companies, [they] can’t just stand down when such an allegation comes in.”


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