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Cooperation in FCPA Investigations – Some Thoughts on Current Incentives and Expectations

TRACE International

Continuing his analysis of the updated Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), John Davis summarizes considerations for companies undergoing FCPA investigations when cooperating with the U.S. Department of Justice (DOJ).  Davis notes that companies must build cooperation credit from zero and highlights examples from recent cases in which the DOJ has given cooperation-related benefits to companies under the CEP.