How the Corporate Enforcement Policy (CEP) Changed Incentives

At the 2025 TRACE Annapolis Forum, Chuck Duross, Global Co-Chair of the FCPA and Global Anti-Corruption Practice at Morrison Foerster, discusses the DOJ’s evolving voluntary self-disclosure policies and the balance of risks and rewards for companies. From increased incentives under the 2025 Corporate Enforcement Policy to the challenges of parallel investigations, Charles explores what drives the decision to self-disclose and why it remains one of the toughest calls in compliance today.