What Can We Expect in Future FCPA Enforcement Actions?

Michael Volkov suggests that patience is needed to see the much-talked-about changes in the DOJ's prosecution of white-collar crime, but the Stericycle FCPA settlement is an early reflection of its new approach, with an emphasis on corporate culture: 1) The assessment of Stericycle’s remediation efforts points to a more stringent standard for reviewing corporate compliance programs and corporate culture.