Remediating an anti-corruption issue is necessary both to get a business back on track and to maximize cooperation credit in any settlement negotiations with the government. But remediating before an internal investigation is complete can be tricky business. Former DOJ FCPA Unit Assistant Chief Laura Perkins, who is now a partner at Hughes Hubbard, recently discussed the importance and challenges of cleaning up an FCPA issue while also cooperating with the government. See also “Top FCPA Officials Encourage Strong Compliance Programs and Remediation, the Defense Bar Responds” (Dec. 21, 2016).
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