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Voluntary Disclosures Under the FCPA
' ' [A]lthough nothing is off the table when you voluntarily disclose, I can tell you in unequivocal terms that you will get a real benefit ' '
Despite these heartening words by Assistant U.S. Attorney General Alice S. Fisher at a recent conference on the Foreign Corrupt Practices Act (FCPA), an attorney representing a corporation cannot recommend voluntary disclosure of potentially criminal FCPA activities without weighing the promise of a 'real benefit' against the very real risks.
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