FCPA Enforcement — Corporate Crime and Punishment
The Justice Department’s reexamination of corporate incentives to disclose violations appears to be in reaction to the steady escalation of cooperation requirements. In response to these extra burdens, DOJ could be concerned that FCPA voluntary disclosures will dwindle. For years, voluntary disclosures have fueled DOJ’s FCPA enforcement program. In the context of a voluntary disclosure program, I have consistently written that DOJ has failed to...