January 30, 2023

James Koukios on Changes to the DOJ Corporate Enforcement Policy

20 minutes

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this special episode, I am joined by Morrison and Foerster partner James Koukios to discuss the recent Kenneth Polite speech announcing changes to the Department of Justice Corporate Enforcement Policy.

In this episode we consider:

What is the CEP;

This is a follow on from the Monaco Memo;

Why this change is significant for recidivists;

How this change redefines an effective compliance program;

The new CEP offers real, tangible and significant benefits for compliance programs; and

What it all means going forward.

Resources

Kenneth Polite Speech

Updated CEP

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