On April 8, 2011, the U.S. Department of Justice announced that it had reached a settlement with Johnson & Johnson and its subsidiaries for Foreign Corrupt Practices Act violations. Compared to prior FCPA settlements, the DOJ elaborated much more specific compliance measures that it expected Johnson & Johnson to take as part of the settlement.  When considered together with the decline in the number of corporate compliance monitors assigned since late 2010, the Johnson & Johnson settlement may signal that the DOJ is considering the use of enhanced compliance requirements in lieu of independent compliance monitors, even in some cases involving companies with multiple FCPA violations.

Click here to read the full article –Getting Specific About FCPA Compliance – written by Scott Maberry, Thad McBride, Mark Jensen and Corey Phelps, that was recently published by Law360 on June 29, 2011.