In the wake of the myriad of scandals that have rocked the corporate landscape in recent years, federal agencies such as the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC), as well as state authorities such as the New York attorney general, have flexed their muscles and sent out a strong, clear message: corporations better cooperate with federal and state investigations, or else.

Indeed, the DOJ, armed with a newfound focus on corporate cooperation with its investigations, has revamped its official set of principles directed at the prosecution of business organizations. 1In the same vein, the SEC has recently assessed massive civil penalties � Worldcom was fined over $2 billion 2 � in part for failure to provide complete or correct information in a timely manner.