Once Again, Rebooting A Long-Standing FCPA Proposal
An article on FCPA Professor proposes that when a company voluntarily discloses an FCPA internal investigation to the DOJ and/or SEC and when one or both of the enforcement agencies do not bring an enforcement action, the enforcement agency should publicly state, in a thorough and transparent manner, the facts the company disclosed and why the enforcement agency did not bring an enforcement action based on those facts.
