Does Voluntary Disclosure Make More Sense After Goodyear?

Law360, New York (March 4, 2015, 8:48 AM EST) -- Last week, the U.S. Securities and Exchange Commission imposed an approximate $16 million disgorgement penalty, but no additional fine, against Goodyear Tire & Rubber Co. The SEC alleged that two of Goodyear's subsidiaries in Kenya and Angola paid $3.2 million in bribes to secure approximately $14 million in private and public contracts over a four-year period between 2007 and 2011.

The issue came to light within the company when a confidential complaint was submitted to Goodyear's ethics hotline in 2011. The complaint resulted in an internal investigation and ultimately led to a voluntary disclosure of the illicit payments to the SEC....

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