In this episode of the FCPA Compliance Report, I visit with Laura Perkins, a partner at Hughes Hubbard & Reed. Perkins formerly worked with the Department of Justice, FCPA Unit, departing in September 2017. We discuss the decision of self-disclosure of a potential FCPA violation to the Justice Department. Some of the highlights include:
- What should a company expect after it makes a decision to self-disclose the to DOJ? What information should be in the initial self-disclosure?
- What should be in the initial investigation plan they present to the DOJ?
- When should remediation begin and how much information does the government want to know about in this area?
- What should a company do to satisfy the government it has secured all documents and communications?
We next turned to the resolution phase and discussed several topics including:
- When is a company ready to present information to the DOJ that it believes the matter should be closed?
- Whether through declination or charging document?
- How is the final penalty decided? and
- Is it through negotiation or simply presented to the company?
For more information on Laura Perkins and Hughes Hubbard & Reed, check out the firm’s website, here.
What are some of the key considerations around self-disclosure and dealing with the DOJ? Laura Perkins explains on FCPA Compliance Report.Click to tweet