Top Justice Department officials have long said companies reap “meaningful” benefits from voluntary disclosure. If federal prosecutors really want to convince companies and encourage self-reporting, a change in enforcement policy is needed, says one former U.S. Deputy Attorney General.
Whether companies reap real benefit from self-reporting violations, particularly in the area of Foreign Corrupt Practices Act enforcement, where cases involving voluntary disclosures have resulted in guilty pleas, huge fines, and other penalties, has been the subject of much debate among the corporate and legal communities.
