Safran's Declination: Successor Liability and Promises Kept Under the FCPA Corporate Enforcement Policy

French aircraft manufacturer Safran’s voluntary disclosure, extensive cooperation and agreement to disgorge the $17.9 million in profits allegedly obtained through its bribery scheme in China were cited by the DOJ as key factors in its decision not to prosecute the company for FCPA violations, seeming to follow-through on the promises made under the FCPA Corporate Enforcement Policy and its 2016 predecessor, the FCPA Pilot Program. The Anti-Corruption Report spoke with Daniel Kahn, a partner at Davis Polk, and James Koukios, a partner at Morrison & Foerster, about Safran’s declination and what it signals for corporate compliance programs. See “Top FCPA Officials Discuss the State of Compliance and Advise on Negotiations, Presentations and When to Cooperate” (December 21, 2022).

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