Partner John Pease spoke with AGENDA regarding a new, uniform policy to gauge cooperation when deciding penalties against companies. The policy lays out incentives for companies to self-report corporate misconduct and notes several factors that could detract from the cooperation credit companies might otherwise receive.
“Having the opportunity to consider a voluntary self-disclosure to a local U.S. attorney’s office is a good thing,” John said.
“But having said that, the calculus is complex because these policies — and this one is no exception — are written with a lot of caveats and a lot of exceptions, and provide, in this case, U.S. attorneys’ offices with a lot of discretion in evaluating whether or not a company meets the criteria, and to what extent they’re going to benefit from it. … There are clearly some issues you really have to think about.”
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