- Considerations Before Self-Reporting Under New FCPA Policy
- December 14, 2017 | Authors: Scott Sorrels; Olga Greenberg
- Law Firms: Eversheds Sutherland (US) LLP - Atlanta Office ; Eversheds Sutherland (US) LLP - Washington Office
On November 29, 2017, the US Department of Justice kicked off the holiday season with a Christmas offering of sorts to companies subject to the US Foreign Corrupt Practices Act with its announcement of a revised corporate enforcement policy. The policy revision makes permanent the core elements of an Obama-era FCPA pilot program and also adds a key benefit to firms considering voluntary disclosures of FCPA violations—namely, that a presumption of no prosecution will apply to those companies that self-report such misconduct in a manner consistent with the DOJ’s standards.In their article for Law360, Eversheds Sutherland attorneys Olga Greenberg, Scott Sorrels, Jeffrey Bialos and Yvonne Williams-Wass discuss several noteworthy aspects of the new enforcement policy and that firms have to carefully assess the potential benefits along with the costs and risks.