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Self-Reporting of FCPA Issues – Some Thoughts on Current Incentives and Expectations

TRACE International

In this post for TRACE International's BriberyMatters blog, John Davis discussed incentives for companies facing self-disclosure in connection with an investigation under the Foreign Corrupt Practices Act (FCPA), as outlined in the Department of Justice's (DOJ) updated Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP). "A key consideration is whether a disclosure allows for preservation of key evidence," Davis said.