In a move that follows long-standing complaints from the corporate community and the FCPA defense bar concerning the Government’s vague assurances of “cooperation credit” in FCPA resolutions for self-reporting companies, on April 5, 2016, DOJ officials announced a new one-year FCPA “pilot program” that outlines a concrete set of standards defining what constitutes cooperation and what credit companies can expect to earn for that cooperation.  Rumors of the program first emerged in late 2015, amid DOJ officials acknowledging a desire to motivate companies to voluntarily self-disclose FCPA-related misconduct, to fully cooperate with the DOJ’s Fraud Section, and to remediate flaws in their controls and compliance programs.  
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