Carrots and Sticks — DOJ's Self-Reporting Policies

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2 Responses

  1. Howard says:

    They could also follow the example of OFAC, which similarly gives significant leniency for self-disclosure.

    But I’m not sure even setting percentages would satisfy critics of the Department in this area. After all, even then, the DOJ would be the ones determining the benefit.

    And while I think there is a benefit to self-disclosure, I would counsel caution to a company considering it. I don’t always agree with the calculus companies use, but there is a calculus to consider.

  1. May 18, 2012

    […] Carrots and Sticks — DOJ’s Self-Reporting Policies: Michael Volkov, Corruption, Crime & Compliance, calls for clearer guidelines about the benefits companies may receive for self-reporting. […]