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‘Turn Yourself In,’ Justice Dept. Says, But Companies Need Data

April 30, 2018, Bloomberg Law

Jennifer Saperstein is quoted in a Bloomberg Law article regarding the Justice Department's decision not to press criminal charges against Dun & Bradstreet Co. because of the company's cooperation under the updated anti-bribery policy. According to Saperstein, Dun & Bradstreet’s approach demonstrated the full benefits the new system can offer, but the DOJ’s decision in this one case won’t immediately change any company’s rationale about self-reporting. “The jury is still out, and companies will still be watching for further settlements," she says. 

Saperstein adds that the DOJ letter didn’t offer a complete picture of the conduct surrounding the case. Without all the facts, it will be hard for other companies to completely understand the DOJ’s reasoning. “A lot of companies look for declinations where there are publicly available fact points,” she says. By choosing to self-report, companies are vying for concrete benefits when the Dun & Bradstreet case doesn’t wholly show them since details surrounding the conduct weren’t disclosed.

Saperstein concludes that although Dun & Bradstreet pretty much hit a home run under the new policy, more cases need to come forward to truly demonstrate the DOJ's thought process. “I wonder, absent the policy, would the results have been different? Would the resolutions with the DOJ be different?” Without more data points, it’s hard to tell what an alternative outcome could have been, she says.

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