Once corruption is confirmed, the organization must decide whether to “Self-Disclose” to authorities like the DOJ (USA) or SFO (UK).
The “Cooperation Credit” Math:
- Full Disclosure: Providing all facts and identifying all individuals involved.
- Remediation: Firing the perpetrators and fixing the control gap before the regulator asks.
- Disgorgement: Giving back all profits earned from the corrupted contract.
- The Benefit: Self-disclosure can lead to a 50% reduction in fines and a “Non-Prosecution Agreement” (NPA), allowing the company to stay in business.
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