Menu6/24/16: Earlier this year, the US Department of Justice announced a pilot program to encourage companies to report potential FCPA violations. The enticement for those companies was the possibility of a reduction of fines set by the US Sentencing Guidelines. Even more enticing, DOJ indicated that it would consider a declination for companies that met the guidelines of the pilot program. In a post on the FCPA Blog, Richard L. Cassin shines a light on those possibilities by reprinting the declination letters released by two companies – Nortek and Akamai – that self-reported FCPA violations and subsequently entered into non-prosecution agreements with the SEC. Notes Cassin, “The Nortek and Akamai declination letters … should help others decide if they want to take advantage of the Pilot Program.”
