| Description: |
After a pause in enforcement, DOJ issued its new FCPA enforcement and compliance strategy. DOJ's strategy is new and contains important statements re enforcement priorities. At the same time, DOJ's strategy includes elements that are consistent with prior policies and guidance. DOJ's continued focus on individual prosecutions is nothing new, but the new focus on national security, U.S. competition, and bribery schemes involving benefits to cartels and transnational criminal organizations raises important issues.
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