Five Key Takeaways from DOJ’s New FCPA Corporate Enforcement Policy

In a new blog post, Michael Volkov discusses some key points in the Department of Justice's new FCPA enforcement policy, including the presumption of declination; the 50 percent discount for companies who don't qualify for a declination; the addition of a root cause analysis requirement to the remediation prong; the role of the chief compliance officer; and document retention requirements.