Should Companies Turn Themselves in for FCPA Violations?

Compliance Insider

, Corporate Counsel


It is easy to understand why the U.S. government encourages voluntary disclosure of actual or potential violations of the FCPA. But is it always the wisest choice for a company to disclose?

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What's being said

  • Seema Sapra

    I reported General Electric corruption, fraud and bribery in India, I was fired, my life systematically destroyed, I was drugged and poisoned, all sources of help were approached and turned against me, my corruption and right to life petition is in the Delhi High court and has not been heard for 6 months. I have been rendered homeless and almost destitute. GE tells the court not to grant me shelter on my shelter application. Attempts are being made to smear me as suffering from mental health issues and as an alcoholic. Please read and The matter is Seema Sapra vs General Electric Co. and Others in the Delhi High Court - Civil Writ Petition No. 1280 of 2012.

    Copies of documents and pleadings filed in Civil Writ Petition No. 1280 of 2012 in the Delhi High Court can be read/ downloaded at

    The corruption involves GE Transportation bids to grab lucrative locomotive factory projects in India on public land, with public funds and with assured long term orders backed by government guarantees.

  • FCPA Veteran Practioner

    Ms. Wragge raises valid and insightful concerns about the wisdom of disclosure. She fails to mention one key consideration however: the highly lucrative revolving door between the SEC/DOJ and law firms. Rumors about that $1 million to start isn't unusual. Why does that matter? Because legal fees for internal FCPA investigations are astronomical to begin with and become stratospheric if a disclosure is planned or a monitor role arises. Thus, the FCPA bar is alive and well and buying up Aspen ski condos. From the point of view of an up and coming SEC or DOJ attorney, private practice looks enticing and secure, particularly if they have made their reputation on big "name" cases. Thus, the pious speeches from regulators about the wisdom of disclosure serve to "feed the beast."

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