A Global Investigations Review article covered a panel discussion moderated by partner Sandra Moser at the International Conference on the Foreign Corrupt Practices Act (FCPA), hosted by the American Conference Institute. The article quoted government officials discussing the various outcomes for companies that self-report potential FCPA violations, noting that it could result in a resolution, a declination, or a closure of the case.
Sandra noted that the possibility of such varied outcomes offers little certainty to companies considering self-disclosure, leading to a candid response from one panelist that giving total certainty on the outcomes of investigations “would not be an effective system.”