DOJ’s New Corporate Enforcement Policy Gets Its First Real-World Test

Key Takeaways - What Happened: The U.S. Department of Justice (DOJ) issued its first department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy for corporate criminal matters. Within days, DOJ applied it to decline prosecution of the French medical device company Balt SAS and its U.S. subsidiary Balt USA in an FCPA bribery matter, while simultaneously indicting two individuals. The declination letter gives companies their first concrete look at what the new framework requires in... By: Beveridge & Diamond PC