John Davis Discusses Key Issues Companies Should Consider During Internal Investigations in the Anti-Corruption Report

"Outside Counsel Perspectives on Key Steps in Internal Investigations"

Anti-Corruption Report

06.10.2020

On a recent webinar, John Davis discussed key issues companies should consider when deciding whether to investigate and report allegations of Foreign Corrupt Practices Act (FCPA) violations. In determining whether to investigate allegations, companies should note that the failure to investigate and stop misconduct "can increase penalties or create other business risks in terms of commercial consequences," Davis said. Once an investigation has concluded, Davis stated the decision to disclose to authorities depends on the facts and circumstances of the situation, noting there are benefits to voluntary disclosure.