James Tillen Discusses Voluntary Disclosures in 2026 on FCPA Compliance Report
Subtitle
"Voluntary Disclosure In 2026: Risk, Reward, And Uncertainty"
Subtitle
"Voluntary Disclosure In 2026: Risk, Reward, And Uncertainty"
James Tillen appeared on the FCPA Compliance Report podcast to discuss the prospect of voluntary self-disclosure amid the Department of Justice's (DOJ) current corporate enforcement strategy. Tillen addressed the increased clarity and potential benefits under the current policy, as well as the fact-specific considerations that continue to influence disclosure decisions, including timing, cooperation, aggravating factors, and prosecutorial discretion. The discussion also previews issues to be explored at the ACI National FCPA and Global Anti-Corruption Conference in Washington, DC, on December 10-11, 2026. Listen to the full episode here.