Global Investigations Review - The law and practice of international investigations

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DOJ’s M&A leniency policy raises incentives and new questions

By Kelly Swanson

08 August 2018

DOJ’s M&A leniency policy raises incentives and new questions Matt Miner

The DOJ’s offer of a declination with disgorgement to companies that quickly self-report foreign bribery by a business they are purchasing increases the incentive to disclose misconduct to prosecutors. But it could also lead to double punishment.