DoJ AAG Blanco FCPA Pilot


On Mar. 10, DoJ AAG Blanco spoke on FCPA enforcement, cooperation.


  • Kenneth Blanco is Acting Assistant Attorney General, in the DoJ's Criminal Division.
  • For last 18 years, was in Assistant US Attorney office for Southern District of Florida.
  • Last 10 years, has been Deputy Assistant Attorney General, in the Criminal Division.
  • Scope of Criminal Division
  • Criminal Division has 600 attorneys in 17 sections and offices, mostly in Washington
  • Including bribery, corruption, organized crime, trade secret theft, money laundering.
  • Frauds using securities, against governments, healthcare, computer and technology.
  • International aspects are Foreign Corrupt Practices Act (FCPA), BSA and kleptocracy.
  • Requires staff to go all over the world to seek evidence and witnesses to build cases.
  • Use international cooperation with foreign partners that permit exchange of evidence.
  • Multi-Jurisdictional Prosecutions
  • Seen increased multi-jurisdictional prosecution of criminal conduct, when conduct is
    transnational in nature and when several countries have prosecutorial authority for it.
  • Countries strengthened domestic law and power to prioritize white collar prosecution.
  • US sought to reach global resolutions, which apportion penalty between jurisdictions.
  • US has seen increase in foreign requests for evidence gathering and legal assistance.
  • Cited DoJ Dec. 2016, $3.5bn Odebrecht action with Brazil, Switzerland, see #30365.
  • Reported that 10 further countries have confirmed their own investigations into firm.
  • Extended FCPA Pilot Program
  • Follows DoJ Apr. 2016 establishment of FCPA pilot enforcement program, see #27109.
  • Provides clear metrics for voluntary self-disclosure, full cooperation, and remediation.
  • Outlines benefit for voluntary self-disclosure of wrongdoing, cooperation, remediation.
  • One-year pilot period ends on Apr. 5, when will evaluating the utility and if to extend.
  • The program will continue in full force until DoJ reach a final decision on those issues.

Regulators DoJ
Entity Types Bank; Corp
Reference Sp, 3/10, 2017, FCPA, BSA
Functions AML; Anti-Bribery; Compliance; Financial; Legal; Operations
Countries United States of America; Cross-Border
Products Corporate
Regions Am
Rule Type Enforcement
Rule Date 3/13/2017
Effective Date 3/13/2017
Rule Id 31432
Linked to Rule :27109
Report Issue 3/15/2017
Report Section AML & Enforcement

Last substantive update on 03/13/2017