The Importance of Voluntary Disclosure in Corporate Enforcement

In the 20 teens this whole idea of voluntary disclosure was a pilot program focused principally on the Foreign Corrupt Practices Act, FCPA. The US Attorney's offices which were also part of the Justice Department but operate in each of the federal court districts have also announced a parallel corporate enforcement policy that includes a voluntary disclosure component. And the third is there is a corporate decision to be made once a self-discovery occurs of a potential criminal violation about whether or not to self-disclose to DOJ.