The Criminal Division's Enforcement Policy: What's New for Companies Deciding Whether to Voluntarily Disclose?

Since the DOJ announced a new policy under which companies that voluntarily disclosed violations of the Foreign Corrupt Practices Act has attempted to encourage companies to voluntarily disclose all manner of criminal misconduct beyond violations of just the FCPA, while general counsels worldwide have been wrestling with the question of whether and when it is in the company's best interest to so disclose.

12 minute read March 01, 2023 at 12:09 AM
By
Jacqueline C. Wolff
The Criminal Division's Enforcement Policy: What's New for Companies Deciding Whether to Voluntarily Disclose?

In 1979, the Department of Justice (DOJ) announced a new policy under which companies that voluntarily disclosed violations of the then newly enacted Foreign Corrupt Practices Act of 1977 (FCPA) would be treated more leniently than those that did not come forward.

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