Lessons Learned from the Legg Mason FCPA Enforcement Action

In a new blog post, Tom Fox says that Legg Mason's deferred prosecution agreement demonstrates that "an entity can make a comeback through some very egregious facts and failure to self-disclose if it meets the remaining components of the new FCPA Corporate Enforcement Policy." Fox notes that DOJ is continuing its recent trend of rewarding companies who fully cooperate with investigations and demonstrate efforts to improve their compliance programs.