All self-disclosure articles

  • Blog post

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

    2017-09-29T11:15:00Z

    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 post

    Is a cup of coffee a reportable FCPA violation?

    2016-10-20T15:45:00Z

    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 post

    Leniency in Petrobras Scandal Means Decision on Self-Disclosure

    2015-11-10T13:15:00Z

    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. ...