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Are settlements a deterrent or a dodge? (FCPA Blog)

The DOJ has unveiled new guidance to federal prosecutors about bringing criminal cases against individuals in instances of corporate wrongdoing. However, to truly deter wrongdoing, one needs effective enforcement directed at both corporations and individuals. If enforcement action is directed only at corporations, company officers and employees under pressure to meet performance targets will not have a meaningful incentive to refrain from improper conduct. Read more

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