Dilemma of Self-Reporting: The FCPA Experience

, New York Law Journal

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In their White-Collar Crime column, Elkan Abramowitz and Jonathan Sack, members of Morvillo Abramowitz Grand Iason & Anello, write: As a practical matter, the decision about self-reporting commonly boils down to whether the client is obligated to report the misconduct; the likelihood of exposure; and the possible benefit of self-reporting or risk of additional sanction from failing to self-report. Because those assessments are often made with little hard information, the judgments and analysis are sometimes very difficult.

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