The FCPA Guidance and Voluntary Disclosures
The FCPA Guidance is an advertisement for the government’s voluntary disclosure program. DOJ and SEC repeat their message – if you voluntarily disclose, you will get a benefit. As demonstrated in the declinations, companies that disclose will receive a benefit. While I am reluctant to point to bring religion into the FCPA arena, the FCPA Guidance describes the disclosure process in a cleansing way, like...