Bloomberg BNA quoted Manatt’s Jacqueline Wolff, co-chair of the firm’s corporate investigations and white collar defense practice, on revisions to the Justice Department’s enforcement policy on the Foreign Corrupt Practices Act. The publication explained that these revisions could be significant, as companies that voluntarily disclose wrongdoing could avoid prosecution as long as they meet certain conditions.
With greater clarity about how the government will treat voluntary disclosure and cooperation in the revised policy, Wolff told the publication, companies have the incentive to come to the government more quickly.
“For public companies that have serious exposure due to the nature and extent of the conduct and that also have the ability and funding to remediate quickly and extensively, the 50% reduction or the presumption of the declination may bring them to the table quicker simply because they have to consider the benefit to their shareholders such reductions may provide,” she said.