Tagged: FCPA disgorgement

Calculating the New Balance Between Disclosure and Non-Disclosure of Potential FCPA Violations

The Justice Department’s new FCPA Corporate Enforcement Policy has altered the balance between disclosure and non-disclosure of FCPA violations.  How is that for a profound grasp of the obvious? All kidding aside, the question is how much has the balance been changed?  I am not sure there will be a significant increase in the number of companies deciding to seek the benefits under the new...