With Alex Brackett, J. Patrick Rowan, George Terwilliger III
Just a week after the U.S. Department of Justice introduced its new Compliance Counsel, and just a month after the DOJ issued the "Yates memo," it is now being reported that the DOJ is considering a new policy that would offer corporations leniency if they voluntarily disclose violations of the U.S. Foreign Corrupt Practices Act and fully cooperate with investigations.