As the Petrobras corruption scandal moves from its initial investigative phase (focusing on the corrupt actions of Petrobras employees), to the investigation of the international companies that did business with the Brazilian national energy company, Europeans that did business with the energy giant now face some challenging decisions around the issue of self disclosure.

The Brazilian lead prosecutor, Deltan Marinazzo Dallagnol, has made clear that companies which do not self-disclose to Brazilian authorities will not be looked upon as favorably as those who come forward. Marinazzo said in a statement, “We will focus on international companies in a second step, and the sooner they come to cooperate, the better for them.”

Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...