Corporate,
Administrative/Regulatory
Dec. 11, 2020
Guidance for developing third-party messaging app policies
In 2019, the Department of Justice announced an important change to its Foreign Corrupt Practices Act Corporate Enforcement Policy concerning one of the conditions that companies must meet to receive “full credit” for “timely and appropriate remediation” in the resolution of an FCPA enforcement action; it declined to require an outright ban on the use of third-party instant messaging applications.
Jack P. DiCanio
Partner
Skadden, Arps, Slate, Meagher & Flom LLP
525 University Ave #1100
Palo Alto , CA 94301
Fax: (650) 470-4570
Email: jack.dicanio@skadden.com
Boston Coll Law School; Newton MA
Emily A. Reitmeier
Litigation Counsel
Skadden, Arps, Slate, Meagher & Flom LLP
In 2019, the U.S. Department of Justice announced an important change to its Foreign Corrupt Practices Act Corporate Enforcement Policy concerning one of the conditions that companies must meet to receive “full credit” for “timely and appropriate remediation” in the resolution of an FCPA enforcement action. The DOJ declined to require an outright ban on the use of third-party instant messaging applications. Rather, companies must demonstrate their “ability to appropri...
For only $95 a month (the price of 2 article purchases)
Receive unlimited article access and full access to our archives,
Daily Appellate Report, award winning columns, and our
Verdicts and Settlements.
Or
$795 for an entire year!
Or access this article for $45
(Purchase provides 7-day access to this article. Printing, posting or downloading is not allowed.)
Already a subscriber?
Sign In