Welcome back to the podcast, Brib, Swindle, or Steel.

I'm Alexandra Addison Rogge, and for today's podcast, we're listening in to Chuck DeRoss's

discussion at the recent Trace Forum of when and whether to make a voluntary disclosure in

today's environment.

Chuck is known to many of you

as a partner with Morrison Forrester and the former chief of the FCPA unit at the Department of Justice.

Here's Chuck. Let me talk about voluntary disclosure. And what I'd like to do today is to talk

about a couple of things. First, what are the origins of kind of the concept around voluntary

disclosure? Why does it exist? What some of the benefits of the pitfalls are, as you sort of think about it,

understand the voluntary disclosure policy history, so how we are, because there is a new

corporate enforcement policy by the criminal division related to voluntary disclosure.

And then ultimately, what are the factors that you should be thinking about?

And look, voluntary disclosure is a very complex topic, and I guess the spoiler alert is,

I don't know that I'm really going to be able to answer your question or what the questions are that are up there today.

I think it really depends on the facts and circumstances.

Regardless of all of the

changes in terms of FCPA enforcement, this issue is still very alive and well. And, you know, I've had

clients recently and as recently as like, you know, last week, like trying to sort of grapple with

these issues and think about them. And so whether you are sort of on the

legal side of things, the compliance side of things, it does matter because frankly there's a short

time fuse that you need to be thinking about this. There are a number of different components in

terms of remediation that play right into the sort of the lane of compliance, sort of root cause analysis

...