Grading DOJ’s FCPA Corporate Enforcement Policy

In a new article, FCPA Professor assesses the Department of Justice's new Corporate Enforcement Policy, including the following areas: (i) the obvious logical gap in the CEP; (ii) how the CEP, both in terms of rhetoric and substance, is really nothing new; (iii) ten specific reasons why the corporate community should take the CEP with a grain of salt; and (iv) how the CEP falls short of accomplishing DOJ's goals compared to other alternatives previously advanced.