DOJ updates Corporate Enforcement Policy to strengthen corporate accountability, transparency

July 21, 2023
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This article was originally published in The Recorder.

The Department of Justice updated its Corporate Enforcement Policy in the first quarter of 2023 to reflect its continued focus on corporate accountability and transparency. The policy provides guidelines as to how the Criminal Division handles corporate criminal matters, including those related to the Foreign Corrupt Practices Act (FCPA) as highlighted in the case study below. The recent updates place significant emphasis on self-disclosure, cooperation, and remediation in order to reduce the risk of monetary penalties, prosecution, and reputational damage. These changes to the policy demonstrate DOJ’s commitment to working with companies against corruption and fraud and providing greater incentives for companies to do so.