For years, approximately the last 15-20 years, the Department of Justice has wanted business organizations under Foreign Corrupt Practices Act (and other scrutiny) to voluntarily disclose conduct in violation of the law (or mere potential violation of the law).
That the DOJ has made various attempts to encourage voluntary disclosure over the years – and every few years seems to tweak its voluntary disclosure and related corporate criminal enforcement policy – is seemingly an indication that its previous policies were not accomplishing the intended results.
As highlighted in this post, last week the DOJ announced revisions to its 2017 Corporate Enforcement Policy (a policy document which encouraged voluntary disclosure and built upon the 2016 FCPA Pilot Program). The revisions were in addition to revisions to the CEP released in early 2019 (see here) as well as late 2019 (see here).
This post takes a trip down memory lane and highlights various speeches by DOJ officials since at least 2006 extoling the virtues of voluntary disclosures.