Tagged: Boston Consulting Group

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...

DOJ Issues New FCPA Declination: Boston Consulting Group Pays $14.4 Million

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.  DOJ has done everything it can do to incentivize voluntary disclosures — many companies are balancing the pros and cons and often deciding NOT to disclose.  Such...