In this episode of the FCPA Compliance Report, I visit Hogan Lovells partner Stephanie Yonekura on the always difficult decision on whether a company should self-disclose a potential FCPA violation or even allegations of a potential FCPA violation to the Justice Department. We consider such questions as:
Yonekura is the Former Acting US Attorney for the Central District of California so she brings a wealth of knowledge to the topic. We consider all of these questions and more in light of the new FCPA Corporate Enforcement Policy and whether it has changed the calculus for self-disclosure or not. We also visit on whether the recent lack of monitors required under DOJ/SEC FCPA enforcement actions is an omen of things to come or not.
She ends with one of the great pieces of advice you can receive, “You don’t want to poke the bear, whether there is no bear to be poked.”