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DOJ FCPA declination points to continuation of policies and importance of robust compliance

A U.S. flag flies in front of the U.S. Department of Justice (DOJ) headquarters building on September 15, 2024, in Washington, DC.
Photo: David Ake/Getty Images

The company’s voluntary disclosure and full and proactive cooperation in the matter were highlighted among the reasons to decline prosecution.

The first bribery DOJ resolution of President Trump’s second term provides initial insights into declinations under the DOJ’s revised Corporate Enforcement Policy. Details have been revealed in an August 7, 2025, declination agreement published by the US Department of Justice’s (DOJ’s) Fraud Section.

The company’s voluntary disclosure and