Sarah Walters and Katrina Rogachevsky wrote this bylined article on the Justice Department’s Foreign Corrupt Practice Act (FCPA) pilot program to incentivize self-disclosure of potential FCPA violations. “Self-disclosure must be seriously considered” the authors wrote, because “the benefits are real, but making such a disclosure is a frightening proposition,” and they cautioned that even with disclosure, “every defense should be explored and raised.”
