Lessons from the FCPA Corporate Enforcement Policy



Sarah Walters and Katrina Rogachevsky wrote this bylined article on the Department of Justice Corporate Enforcement Policy pilot program, now formally adopted. The pilot program showed, wrote the authors, that “now more than ever, self-disclosure must be seriously considered. While disclosing a potential FCPA violation is still a frightening proposition for many companies, the pilot program … demonstrates that the benefits of self-disclosure are very real.”