Department of Justice Announces New Foreign Corrupt Practices Act Self-Reporting Pilot Program and Accompanying Guidance
On April 5, 2016, the U.S. Department of Justice (“DOJ”) issued a memorandum (“Fraud Section Memo”) announcing a new one-year pilot program designed to encourage companies to self-report violations of the United States Foreign Corrupt Practices Act (“FCPA”) and to cooperate with the DOJ’s Fraud Section. This new pilot program builds upon the DOJ’s previously released Yates Memo, issued in September 2015, which articulated the Justice Department’s priority to hold individuals accountable for an organization’s misconduct.