Dilemma of Self-Reporting: The FCPA Experience

January 8, 2014 | New York Law Journal

Self-reporting misconduct is one of the most difficult judgment calls faced by white-collar defense counsel and their clients. While voluntary disclosure is said to be rewarded by the government, the benefits are often quite difficult to make out. This article examines the dilemma of self-reporting in the context of the federal government's enforcement of the FCPA.