Generally, there is no legal obligation for a company to self-report. While government officials say they give credit for self-reporting, in-house counsel often fear that the opposite is the case. They may escape government scrutiny if they keep quiet, but if they self-report they will receive no credit and instead be punished with a significant fine or worse.
What, then, should in-house counsel do when confronted with a situation that may give rise to a government investigation? This article offers a five-step analysis of this difficult issue.
