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From Baksheesh to BriberyUnderstanding the Global Fight Against Corruption and Graft$
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T. Markus Funk and Andrew S. Boutros

Print publication date: 2019

Print ISBN-13: 9780190232399

Published to Oxford Scholarship Online: May 2019

DOI: 10.1093/oso/9780190232399.001.0001

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PRINTED FROM OXFORD SCHOLARSHIP ONLINE (oxford.universitypressscholarship.com). (c) Copyright Oxford University Press, 2020. All Rights Reserved. An individual user may print out a PDF of a single chapter of a monograph in OSO for personal use. date: 24 November 2020

Voluntary Disclosures

Voluntary Disclosures

(p.637) 25 Voluntary Disclosures
From Baksheesh to Bribery

Andrew Boutros

Oxford University Press

In the course of doing business, company managers may discover that the company has violated the law, thereby exposing the company to potential civil or criminal liability. When this occurs, an inevitable question is whether the company should voluntarily disclose this information to the government. To be sure, the U.S. Department of Justice (DOJ) has strongly encouraged companies to self-report their misdeeds. However, disclosure is not without serious risks and potential consequences. Determining whether to self-report requires careful evaluation of multiple considerations. This chapter discusses in depth those considerations, and fully outlines both the benefits and risks of voluntary disclosure.

Keywords:   FCPA, foreign official, bribery, corruption, anti-corruption, voluntary disclosure, self-report

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