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Ropes & Gray Considers Self-Reporting and Disclosure Obligations in Second Edition of GIR’s “The Practitioner’s Guide to Global Investigations”

Practices: Anti-Corruption / International Risk

A cross-office team of attorneys in Ropes & Gray’s anti-corruption and international risk practice has co-authored two chapters for the second edition of Global Investigations Review’sThe Practitioner’s Guide to Global Investigations”. The comprehensive guide examines how companies should approach each stage of a corporate investigation.

The chapters consider the advantages and disadvantages of self-reporting in the U.S. and the UK, including how the manner and timing of a self-report can make a crucial difference to mitigating potential penalties that might be imposed.

The UK perspective on self-reporting is co-authored by co-chair of Ropes & Gray’s global anti-corruption and international risk practice Amanda Raad, counsel Arla Kerr, and associates Joanna Torode and Mair Williams. The chapter examines guidance from the Serious Fraud Office and the Financial Conduct Authority, as well as identifies advantages and risks of self-reporting and best practices related to the timing of disclosure.

The U.S. perspective on self-reporting is co-authored by Ms. Raad, counsel Sean Seelinger and Arefa Shakeel, and associate Jaime Orloff Feeney. The chapter evaluates mandatory and voluntary self-reporting approaches, Department of Justice co-operation credit, the impact of the Yates Memorandum and role of the Foreign Corrupt Practices Act Pilot Program. It also examines the U.S. Securities and Exchange Commission co-operation credit, and risks to voluntarily self-reporting, as well as those associated with a decision not to self-report.

In addition, the introduction to Part I, the section of the guide focused on Global Investigations in the UK and the U.S., is co-authored by co-lead of the firm’s London anti-corruption and international risk practice Judith Seddon.

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