Voluntary Disclosures Under the FCPA: Is the Promised Benefit Real?

The Foreign Corrupt Practices Act makes it a crime for individuals or companies to make or offer a bribe to a foreign official to obtain or retain business. Covington & Burling’s Jacqueline C. Wolff and Pamela Sawhney provide a review of the past five years of FCPA prosecutions and voluntary disclosures. While government officials encourage companies to disclose possible wrongdoing voluntarily, Wolff and Sawhney warn that companies may want to weigh the real benefits — and risks — before taking that step.

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