Flip-Flop On The Merits Of Voluntary Disclosure
One common frustration with FCPA enforcement is the extent to which government enforcement attorneys say one thing while with the government and then say another thing (often contradictory) when they leave the government. For example, while serving as deputy chief in the Fraud Section of DOJ’s Criminal Division, Charles Duross urged companies to voluntarily disclose potential misconduct as soon as possible. However, after leaving government service, Duross is quoted as saying self-reporting is probably not worth it.
