DoJ’s FCPA Enforcement Plan brings greater clarity rather than change

Nathaniel Edmonds is a partner, Morgan Heavener is of counsel and Ian Herbert an associate in the Washington DC litigation department of law firm Paul Hastings. Contact them on nathanieledmonds@paulhastings.com , morganheavener@paulhastings.com  and ianherbert@paulhastings.com.

The United States Department of Justice’s new Enforcement Plan and pilot programme articulate more clearly than ever what is required from companies in terms of self-disclosure, cooperation and remediation of corruption issues as well as the specific benefits that may be available. But Nathaniel Edmonds and Morgan Heavener report that this may not significantly change the calculus for firms facing a potential investigation.