19
Mar
By Thompson Hine LLP
On March 1, 2018, DOJ attorneys, speaking at the ABA’s annual White Collar Crime Conference, indicated that DOJ may consult the FCPA Corporate Enforcement Policy for guidance in other areas of corporate criminal prosecution when assessing whether voluntary self-disclosure may justify declination. John Cronan, acting head of the Criminal Division, and Benjamin Singer, chief of the Securities and Financial Fraud Unit, highlighted DOJ’s decision to forgo prosecution of Barclays PLC as an example of the application...