There is no legal obligation to voluntarily disclose actual violations of the Foreign Corrupt Practices Act, something even the DOJ has acknowledged various times. But then again, returning to an issue first highlighted in this 2009, voluntary disclosure is the fuel that feeds FCPA enforcement and is extremely lucrative for FCPA Inc. Indeed, who can forget the words of the former DOJ Fraud Section Chief in this Wall Street Journal article “if you get two of these [FCPA investigations] a year as a partner, you’re pretty much set.”
Lennox International is involved in the heating, air conditioning, and refrigeration markets.
This October 2016 post asked what made Lennox so hot that it disclosed to the DOJ and SEC an investigation into a $475 payment in Russia to release a shipment of goods being held by customs officials.