Humorous
It is always a bit humorous (among other things) when a former FCPA enforcement official changes his/her position on a topic when they leave the government and go into or back into private practice (as nearly all do).
While at the DOJ, Daniel Kahn (like other FCPA enforcement officials) was a big proponent of voluntary disclosure.
However, in this Law360 article, commenting on recent DOJ policy charges (see here for the prior post) Kahn stated that the discount for companies that self-disclose is a nice reward, but that there is still a question about whether it will incentivize companies to report if they were otherwise not inclined to disclose or cooperate.