ABB is a three-time loser in foreign bribery enforcement but still agreed to pay $315 million to settle FCPA charges. The company also resolved SEC charges for $75 million. .
DOJ Criminal Division’s CEP, expanding the availability of a potential full declination with self-reporting, even in some cases involving aggravating circumstances, and applying the CEP to a broader range of issues, including those involving fraud and money laundering.
On January 17, 2023, the Department of Justice (DOJ), Criminal Division, announced it has reassessed and strengthened its Corporate Enforcement Policy, which applies to all corporate.