Voluntary Disclosure: The Continuing FCPA Debate

Law360, New York (November 21, 2014, 9:54 AM EST) -- The U.S. Department of Justice and the U.S. Securities and Exchange Commission regularly urge companies and Foreign Corrupt Practices Act practitioners to disclose FCPA violations to the DOJ in order to earn a possible declination, deferred purchase agreement or a reduced penalty.

The DOJ has been criticized for failing to define exactly how it assesses cooperation and how much of a discount companies earn by cooperating. In response, the DOJ has tried to be more transparent. The FCPA guidance sets out factors the DOJ takes into...
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