All self-disclosure articles

  • CFTC

    CFTC guidance details path to reduced enforcement penalties


    The CFTC issued guidance that spells out how companies that self-report violations, cooperate with investigators, and remediate their issues can qualify for a “substantially reduced penalty” on any subsequent enforcement action.

  • Blog

    CFTC makes pitch for self-reporting, cooperation in enforcement actions


    The CFTC, with lessons learned and expectations informed by similar programs at other federal agencies, is promoting new self-disclosure and cooperation agreements with the firms it oversees. James McDonald, director of the Division of Enforcement, outlined the program in a recent speech.

  • Blog

    Is a cup of coffee a reportable FCPA violation?


    What’s next on the list of FCPA violations, a cup of coffee bought for a custom official while you await inspection? Tom Fox ponders that question after reading about Lennox International’s $475 facilitation payment Justice Department disclosure.

  • Blog

    Leniency in Petrobras Scandal Means Decision on Self-Disclosure


    As the Petrobras corruption scandal moves to the investigation of international companies that did business with the Brazilian national energy company, Europeans companies now face some challenging decisions around the issue of self disclosure. Our Man From FCPA, Tom Fox, has more inside about the considerations you need to make.