All self-disclosure articles
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News BriefFlex says no action by OFAC into possible sanctions violations
Flex disclosed in a public filing the Office of Foreign Assets Control is taking no action into potential sanctions violations the global manufacturer voluntarily self-disclosed in 2019.
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News BriefDOJ orders Baptist Health to pay $1.5M over discount policy false claims
Florida-based Baptist Health System agreed to pay $1.5 million to settle self-disclosed violations of the False Claims Act for allegedly offering discounts to patients to induce purchases or refer services reimbursed by Medicare.
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ArticleCFTC guidance details path to reduced enforcement penalties
The CFTC issued guidance that spells out how companies that self-report violations, cooperate with investigators, and remediate their issues can qualify for a “substantially reduced penalty” on any subsequent enforcement action.
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Blog
CFTC makes pitch for self-reporting, cooperation in enforcement actions
The CFTC, with lessons learned and expectations informed by similar programs at other federal agencies, is promoting new self-disclosure and cooperation agreements with the firms it oversees. James McDonald, director of the Division of Enforcement, outlined the program in a recent speech.
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Blog
Is a cup of coffee a reportable FCPA violation?
What’s next on the list of FCPA violations, a cup of coffee bought for a custom official while you await inspection? Tom Fox ponders that question after reading about Lennox International’s $475 facilitation payment Justice Department disclosure.
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Blog
Leniency in Petrobras Scandal Means Decision on Self-Disclosure
As the Petrobras corruption scandal moves to the investigation of international companies that did business with the Brazilian national energy company, Europeans companies now face some challenging decisions around the issue of self disclosure. Our Man From FCPA, Tom Fox, has more inside about the considerations you need to make.