Title

DOJ Clarifies Position on Agency Liability under the FCPA post-Hoskins; New FCPA Chief Named
Client Memorandum

Created date

12/9/2019

Assistant Attorney General Brian Benczkowski, the head of DOJ’s Criminal Division, recently gave a speech in which he clarified that DOJ will not automatically seek to impose agency liability on parent companies for FCPA violations by subsidiaries, joint ventures, and affiliates.  Mr. Benczkowski also announced a new permanent chief of the Fraud Section’s FCPA Unit, and in response to questions from the audience, he stressed the Criminal Division’s desire to reduce protracted negotiations over corporate resolutions.