Question: In 2017, after a one year pilot program, the DOJ made its self-reporting program under the FCPA permanent, with a few minor modifications. How effective

In 2017, after a one year pilot program, the DOJ made its self-reporting program under the FCPA permanent, with a few minor modifications. How effective do you think this new permanent program is likely to be in practice? What challenges might companies face in complying with the program's requirements? Are there areas in which corporations might need more guidance than currently exists? What specific kinds of guidance would you recommend?

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