The U.S. Sentencing Guidelines in FCPA Matters: Understanding the True Impact on Settlement Discussions

The U.S. Sentencing Guidelines (“Guidelines”) play an important, and often misunderstood, role in the final resolution of Foreign Corrupt Practices Act (“FCPA”) investigations involving the U.S. Justice Department (“DOJ”). Those unfamiliar with the Guidelines often make two opposite, but equally significant, mistakes in interpreting them.

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