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Homer Moyer Quoted on the New FCPA Corporate Enforcement Policy in MLex Market Insight

Subtitle
"White Collar Bar Welcomes New FCPA Policy with Caution"

MLex Market Insight

Homer Moyer was quoted regarding the new Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy that was announced on November 29, 2017. Members of the white collar bar welcomed the new Policy, but they also conditioned their assessments on the approach taken by prosecutors in implementing it. The new policy establishes a presumption that a company that makes a voluntary disclosure and satisfies other conditions will get a declination. "This is a significant new incentive for corporations to make voluntary disclosures and cooperate," Moyer said. He sees the presumption as a solid improvement that will give corporate directors greater comfort when weighing the tough call on whether to make a voluntary disclosure of suspected wrongdoing.