The Pilot Program in Practice: A Comparison of Pre- and Post-Program Resolutions

The Department of Justice recently signaled major developments in its anti-bribery enforcement initiatives with the release of its Foreign Corrupt Practices Act Enforcement Plan and Guidance and the announcement of its yearlong pilot program. But, will the DOJ’s new and improved enforcement protocol result in benefits to companies who choose to self-report, cooperate and remediate? In a guest article, Ropes & Gray’s Ryan Rohlfsen, Timothy Farrell and Dante Roldan examine – and provide detailed charts illustrating – the differing outcomes of DOJ cases before and after the recent policy announcements. See also “Going Deep on the Fraud Section’s FCPA Pilot Program” (Apr. 20, 2016); “How Will the Fraud Section’s Pilot Program Change Voluntary Self-Reporting?” (May 4, 2016); and “Earning Cooperation Credit Under the Fraud Section’s FCPA Pilot Program” (May 18, 2016).

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