New Study Finds That Voluntary Disclosure of FCPA Violations Does Not Measurably Reduce Penalties

    View Authors September 2012

    The Department of Justice and Securities & Exchange Commission have long promised that companies will receive a tangible benefit for voluntarily disclosing violations of the Foreign Corrupt Practices Act (FCPA). Not so, says a recent draft study by two New York University School of Law professors, which examined FCPA enforcement actions from 2004 through 2011. Their study found no discernible evidence that voluntary disclosure of FCPA violations resulted in lesser penalties.