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FCPA Case Shows Benefit of Self-Disclosure

Melissa Klein Aguilar | October 30, 2007

Amid a flurry of recent enforcement actions, stiff fines and painful public scoldings, prosecutors recently settled a Foreign Corrupt Practices Act case that demonstrates self-disclosure of such offenses can indeed bring some benefits to a company.

The case involves a Dutch software company, Paradigm, that caters to the oil and gas industry. After the company relocated its principal place of business from Israel to Texas in 2005, it discovered it had either made or promised numerous bribes to officials in five nations. The company pre-emptively confessed to Justice Department prosecutors, instituted remedial compliance measures, and ultimately ended up with an 18-month non-prosecution agreement. After that, assuming no further trouble, the case will be closed.

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