What to Consider When Deciding Whether to Self-Disclose: An Interview With Steptoe’s Lucinda Low

The laundry list of variables affecting a decision to self-report seems almost endless. Considerations about whistleblowers, pressure from auditors worried about their own liability, the prospect of multijurisdictional investigations, the likelihood of collateral consequences and even the sometimes elusive benefits of self-disclosure all factor into the mix. The Anti-Corruption Report spoke with Lucinda Low, a partner at Steptoe, about the self-reporting calculus – from the basics of disclosure to nuances that may be experienced in any particular set of circumstances. Excerpts from the interview follow. See also “Former DOJ Prosecutors Weigh In on Self-Reporting, Individual Prosecutions, International Cooperation and Enforcement Tactics” (Nov. 4, 2015).

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