Sanctions Enforcement: Embracing the FCPA playbook?
Early last year, when Deputy Attorney General Lisa Monaco began describing sanctions as “the new FCPA,” she didn’t mean sanctions enforcement would replace the FCPA. She meant the DOJ is working to replicate the success of FCPA enforcement by using some of the same strategies — a high-intensity focus on finding and punishing violators, deploying innovative tools, promoting international cooperation, and so on.