Life Science Compliance Update

June

2016

Is the Carrot Bigger Than the Stick? – The DOJ’s FCPA “Pilot Program”

Written by , Posted in Enforcement

Kurt Stitcher, Senior Compliance Consultant

The U.S. Department of Justice’s FCPA Pilot Program is nominally designed to encourage voluntary self-disclosure of FCPA violations by providing more certainty around the outcome of such disclosure.  The price of this “certainty” is fairly onerous, however, and the program suffers from many ambiguities and flaws that make it only marginally useful to Life Sciences companies when structuring compliance programs and determining the benefits of voluntary self-reporting.


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