Canada’s enforcement landscape may be changing. The Canadian legislator appears to be signalling a will to increase enforcement of the Corruption of Foreign Public Officials Act (CFPOA) (as well as other economic crimes) with the September 2018 adoption of the new Canadian Deferred Prosecution Agreement (DPA) regime, also called the Remediation Agreement regime. The Remediation Agreement regime appears to place a greater focus on the importance of internal controls.

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