Corporate
Apr. 27, 2016
FCPA program continues focus on individuals
Whether or not to self-report violations of the Foreign Corrupt Practices Act has constituted a problematic and vexing question for companies when confronted with internal allegations of potential foreign bribes.
Debra Wong Yang
Partner
Gibson, Dunn & Crutcher LLP
333 S Grand Ave
Los Angeles , CA 90071
Phone: (213) 229-7000
Email: dwongyang@gibsondunn.com
Boston Coll Law School; Newton MA
Debra is a partner in the firm's Los Angeles office. Reflective of her broad practice and comprehensive abilities, Ms. Yang is Chair of the Crisis Management Practice Group, former Chair of the White Collar Defense and Investigations Practice Group, which includes the FCPA Practice Group and former Chair of the Information Technology and Data Privacy Practice Group. She is also a member of the firm's Executive Committee.
Michael Li-Ming Wong
Gibson, Dunn & Crutcher LLPPhone: (415) 858-7400
Email: mlwong@willkie.com
Harvard University Law School; Cambridge MA
Wesley Sze
Associate Attorney in the Artificial Intelligence Practice Group
Gibson, Dunn & Crutcher LLP
Whether or not to self-report violations of the Foreign Corrupt Practices Act has constituted a problematic and vexing question for companies - and their counsel - when confronted with internal allegations of potential foreign bribes. While the U.S. Department of Justice has long made vague promises of rewarding self-disclosure with "credit" for cooperation, the lack of any specific guidance stymied companies' abilities to quantify that potential credit in any meaningful way.
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