Christmas comes early - The FCPA Pilot Program made permanent

On 29 November 2017, a year since its inception, the Department of Justice ("DOJ") announced that the Pilot Program will now be permanent.

In response to wide criticism from practitioners, that more clarity about how the program works was needed, the DOJ enhanced the FCPA Corporate Enforcement Policy ("Policy") to provide more detail about its decision making in cases.

FRA's Jenny McVey reviews in LSC Update some of the key highlights outlined by the DOJ and some considerations for compliance professionals.