FCPA Compliance Report

James Koukios on Changes to the DOJ Corporate Enforcement Policy

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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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