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Benefits to Voluntary Disclosure: DOJ Does Not Act as a Star Chamber

From time-to-time, I am fortunate to have a guest post on my blog by Mike Volkov which are always informative and provocative. Last Friday, Mike continued this tradition of both as he posed the question of whether the Department of Justice (DOJ) voluntary disclosure process operates as a " Star...

Sometimes No Evidence is Meaningless: Voluntary Disclosure under the FCPA

The Foreign Corrupt Practices Act (FCPA) world went crazy last week with headlines along the lines of "No credit for self-reporting"; "No credit for cooperation"; and "Voluntary disclosure doesn't change penalties". All of these pronouncements were based upon a draft...

Issues to Consider From the Louis Berger Enforcement Action

This article was reprinted with permission from FCPA Professor This recent post highlighted the DOJ FCPA enforcement action against Louis Berger International (LBI) and two former employees. This post continues the analysis by highlighting various issues to consider from the enforcement action...