Tips For Disclosing A Possible FCPA Violation

Law360, New York (July 22, 2013, 4:54 PM EDT) -- The Internet is filled with articles written by lawyers, consultants and government officials on when a company should disclose a potential Foreign Corrupt Practices Act violation or a government FCPA investigation. It is not an easy question, and lawyers often disagree on when a matter is “material” for a publicly traded company.

The disclosure has major ramifications for a company. I am amazed at how quickly the plaintiffs' bar reacts to an FCPA violation disclosure (as well as other disclosures). Within weeks of a disclosure, I...
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