Episode 336 — Review of Recent DOJ Declinations
The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination. But even a declination comes with a requirement: the company has to pay disgorgement In the latest declination case, Boston Consulting Group (“BCG”) earned a declination for FCPA violations stemming from conduct in Angola. BCG, a management consulting firm, earned the declination...