James Koukios on Changes to Corporate Enforcement Policy

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 the following:

  • 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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