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One of the most difficult and consequential decisions a company faces when presented with a corruption allegation is the decision whether or not to self-report to the government. On the one hand, Foreign Corrupt Practices Act (FCPA) enforcement officials uniformly cite voluntary self-disclosure as one of the most critical elements of the government’s decision to award cooperation credit. On the other hand, companies risk unnecessary costs and negative publicity when self-reporting where the underlying facts may not otherwise warrant an enforcement action. Compounding the issue is the fact that companies generally achieve the maximum benefit from self-reporting when they contact the government at the earliest stages of the investigation—often before all the facts are known.