Judge Refuses to Approve a Joint Consent Motion Despite Government Championing Corporate Self-Disclosure

The government’s blessing is no longer the last hurdle to resolution of an international corruption investigation even when a company provides selfdisclosure of its conduct. Declaring he is not “a rubber stamp,” a federal judge refused to approve a deferred prosecution agreement despite the company’s voluntary selfdisclosure, cooperation and remediation efforts, and precarious financial condition. The judge wanted harsher sanctions.