Voluntary disclosure of potential FCPA violations is a tricky issue, made even more difficult given the potential conflict of interest FCPA counsel has in advising the company as to the important disclosure issue, particularly where the disclosure only involves a potential FCPA violation.
This article, by three authors from Steptoe & Johnson, presents an overview of some of the particular issues and challenges that companies may face in conducting internal investigations in the area of export controls and economic sanctions compliance.
This article by Richard Matheny of Goodwin Procter LLP briefly discusses a three-phase approach to the internal investigation of suspected violations of export-controls and economic-sanctions laws.
Depending on a company’s ultimate objectives, having the correct balance within the control structure is the key to a successful internal fraud investigation.
