I recently provided comments for an article in the Anti-Corruption Report examining recent Department of Justice (DOJ) settlements under the Foreign Corrupt Practices Act (FCPA).

In two of the settlements, U.K.-based reinsurance brokers settled charges for more than $47 million in penalties and disgorgement; a third entity paid no fines and was only subject to disgorgement. According to the DOJ, all three entities had bribed Ecuadorian government officials to win contracts. The company that disclosed its violations was the one that paid no fines.

I noted the matters demonstrate that “there’s a clear, explicit benefit for companies to disclose.” In addition, I explained that self-disclosure allows companies to control the narrative and take greater control of the investigation into the matter.

The full article, “Reinsurance Brokers’ Settlements Highlight Growing Emphasis on Cooperation Credit,” was published by the Anti-Corruption Report on December 20 and is available online (subscription required). I wrote about this FCPA enforcement action for a blog post on December 14 titled, “Foreign Corrupt Practices Act Update: Considerations Around Voluntary Disclosures.”