The Role of Compliance in Federal Criminal Prosecutions

The concept that started out as focused strictly on FCPA was broadened and now applies to all federal criminal prosecutions. If a company meets the criteria and self discloses, OJ will start actually below the bottom of that range in looking at what fine or penalty they may invoke. This is a very high level recitation of a very technical area so of course consult your local criminal defense counsel. And I can tell you from all my years doing this I don't think our industry pays enough attention to DOJ's guidance documents unless they're responding to some indictment or some criminal investigation.