WEBCAST: To Disclose or Not to Disclose: Weighing the Costs and Benefits of Voluntary Disclosure Under the DOJ’s FCPA Corporate Enforcement Policy
Date/Time Tuesday, December 12, 2017 at 5:00 PM GMT/UTC
Duration 60 Minutes
Handout Materials
Presentation Slides
FCPA Enforcement Plan
US DOJ FCPA Guide 2012
FCPA Checklist for CEOs
Presented by ACC's New to In-house Committee and Sponsored by Saul Ewing Arnstein & Lehr LLP
Since the U.S. Department of Justice announced its FCPA “Pilot Program” in April 2016, and the subsequent extension of the program in March 2017, several companies have benefited from voluntary disclosures of FCPA violations. These benefits may include outright declinations or reductions in sentencing exposure. But the benefits of disclosure also carry risks, and from the perspective of individual executives and employees, DOJ’s heightened scrutiny of individual accountability offers little comfort for would-be FCPA violators. This presentation will suggest cost-benefit considerations for companies, while emphasizing the importance of continued rigorous compliance policies and practices following DOJ’s permanent adoption of the “Pilot Program,” as announced by Deputy Attorney General Rod Rosenstein on November 29, 2017.

Justin Danilewitz, Partner, White Collar and Government Litigation, Saul Ewing Arnstein & Lehr LLP

Peter Bowe, CEO, Ellicott Dredges, LLC


Rodolfo Rivera, Chief International Counsel, Fidelity National Financial


This archived program is free to view. CLE/CPD is not available.


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