United Technologies Corporation, a building systems and aerospace conglomerate, recently settled bribery issues with the SEC after the DOJ declined to prosecute. Despite media reports of the corruption that pre-dated the company’s report to the government, the company won full credit for self-disclosure and cooperation from U.S. authorities and paid a total of just under $14 million. The case illustrates the value of being forthright with the government and offers lessons about what makes entertainment expenses pass SEC muster. See our two-part series on how to answer the question “There’s a problem, now what?”: “Philip Urofsky of Shearman Explains the Logistics of Self-Reporting” (Sep. 14, 2016); and “Richard Smith of Quinn Emanuel Discusses Framing Voluntary Disclosure to Minimize Cost and Maximize Credit” (Mar. 15, 2017).