February 2007

Is the Promised Benefit Real?

By Jacqueline C. Wolff and Pamela Sawhney

“ … [A]lthough nothing is off the table when you voluntarily disclose, I can tell you in unequivocal terms that you will get a real benefit … ” Despite these heartening words by Assistant U.S. Attorney General Alice S. Fisher at a recent conference on the Foreign Corrupt Practices Act (FCPA), an attorney representing a corporation cannot recommend voluntary disclosure of potentially criminal FCPA activities without weighing the promise of a “real benefit” against the very real risks.

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