Bass, Berry & Sims attorney Wally Dietz was interviewed and quoted for an article providing insights on when companies should self-report potential violations of the Foreign Corrupt Practices Act (FCPA) to government regulators. As Wally points out, the U.S. Sentencing Guidelines give credit to companies that report misconduct in a "reasonably prompt" time frame, which could even be the few months it may take to quickly launch an internal investigation, review all financial records and documents and conduct witness interviews. Because the company loses control over the situation once it provides voluntary disclosure to the government, it is important that the company has a firm grasp of the situation and all related compliance issues.
The article, "The Multimillion Dollar Question: When to Self-Report," was published by Compliance Week on April 28 and is available online (subscription required).