Number of DOJ Declinations Sees "Notable Uptick" Following FCPA Pilot Program

April 11, 2017

James Tillen and Marc Bohn from law firm Miller & Chevalier found that the Department of Justice’s (DOJ) one-year enforcement “pilot program” aimed at promoting greater accountability for those who violate the U.S. Foreign Corrupt Practices Act has been accompanied by “a notable uptick in declinations by the department.”

Writing for Law360, Tillen and Bohn “identified a record 15 DOJ declinations in 2016, along with another six DOJ declinations in 2017 to date, which puts the department on pace for another record year.”