… Companies that can demonstrate a truly proactive approach to anti-corruption compliance, both before a problem arises and after an allegation is received, can do much to help themselves in order to obtain the real golden carrot – the much-desired “declination” from the U.S. Department of Justice (“DOJ”) and similar treatment from the Securities and Exchange Commission (“SEC”). Not every case is appropriate for a declination – the strategy for each case must be carefully considered on its own merits. The following is the roadmap for those with the right facts and interest in pursuing the goal of a formal declination from the U.S. government.
via FCPA Declinations: How to Maximize Your Chance to Get a Pass When a Corruption Problem Occurs — Paul Hastings Client Alert
