Creating Value in FCPA Investigations Through Increasing Cooperation Credit

When payments to a third party with possible connections to the government are discovered in a high-risk market, what is a general counsel to do? This guest article, featuring a hypothetical narrative, tracks the trials and tribulations of a general counsel confronted with such an FCPA matter. Baker Donelson partner Joe Whitley and associate David Stewart provide specific advice about how a GC can successfully navigate an internal corruption investigation from the initial fact discovery to negotiating for sufficient resources to addressing collateral consequences. See “Brockmeyer and Stokes Offer Four Benefits of Cooperation and Four Ways Companies Can Go Wrong in Their Internal Investigations” (Dec. 16, 2015).

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