The DOJ continues to promote the voluntary disclosure of FCPA issues and claims that its policies – notably the Pilot Program issued in April 2016 and recently revised and added to the U.S. Attorneys’ Manual as the FCPA Corporate Enforcement Policy – have led to an increase in voluntary disclosures. In a guest article, Baker & Mackenzie partner Richard Dean discusses the factors companies must weigh when evaluating whether to self-disclose a potential FCPA violation. See “DOJ’s FCPA Corporate Enforcement Policy: What’s New and What’s Not (Part One of Three)” (Jan. 10, 2018); Part Two (Jan. 24, 2018); Part Three (Feb. 7, 2018).