DOJ Announces FCPA Enforcement Strategy and New Self-Reporting Pilot Program

On April 5, 2016, the U.S. Department of Justice (“DOJ”) announced a three-step enhanced Foreign Corrupt Practices Act (“FCPA”) enforcement strategy.  The strategy includes increasing the number of staff dedicated to FCPA investigations, increased coordination with foreign law enforcement officials, and a pilot program aimed at encouraging companies to self-report FCPA misconduct by providing greater transparency into the steps required to gain cooperation credit and the kind of credit available to companies that do self-report.   The guidelines for the pilot program detail the DOJ’s requirements for companies to receive credit for (i) voluntary self-disclosure, (ii) “full cooperation,” and (iii) “timely and appropriate remediation,” and provide a mechanism for companies that meet these requirements to receive significant cooperation credit when resolving an FCPA investigation.