How Can Individual Defendants Use Strategic Cooperation to Mitigate FCPA Sentences?

Individuals at risk for FCPA charges can benefit from approaching and cooperating with the government as early as possible.  Working from recent DOJ sentencing memoranda, this article focuses on how actual and potential individual FCPA defendants (and their counsel) can approach cooperation in a way that is likely to lead to reduced sentences.  In particular, this article focuses on the content, timing and required utility of cooperation.

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