Fraud Prevention and Detection

BRIBERY AND CORRUPTION

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same. Of course, voluntary disclosure is not the only factor we con-

sider in deciding how to resolve a particular case. We take into account

all the factors set forth in the Principles of Federal Prosecution of Business

Organizations, and we consider the particular facts and circumstances

of each individual case. But there is no doubt that a company that

comes forward on its own will see a more favorable resolution than

one that doesn’t.

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But the costs of internal investigations—especially for a multinational

company—can be signicant. Siemens, for example, hired more than

300 lawyers, forensic accountants, and support ...