tag:blogger.com,1999:blog-3249858307559481775.post1602173749095659899..comments2024-01-03T04:30:53.036-05:00Comments on FCPA Professor: A Happy EndingMike Koehlerhttp://www.blogger.com/profile/15749973007274251992noreply@blogger.comBlogger2125tag:blogger.com,1999:blog-3249858307559481775.post-12067612666277023502010-04-05T19:53:08.452-04:002010-04-05T19:53:08.452-04:00Mike,
Thanks for your comment. While possible, m...Mike,<br /><br />Thanks for your comment. While possible, my guess is that is not the case. As noted in the post, this was not a pure (or traditional) voluntary disclosure.Mike Koehlerhttps://www.blogger.com/profile/15749973007274251992noreply@blogger.comtag:blogger.com,1999:blog-3249858307559481775.post-9846969573132835602010-04-05T10:09:58.509-04:002010-04-05T10:09:58.509-04:00Could this be a case that because the company had ...Could this be a case that because the company had a compliance program in place that fit the Sentencing Guidelines, DOJ decided not to proceed? If so, it would be another reason for all entities doing business overseas to review their programs to detemine if they follow the Guidelines.Mike Osajdanoreply@blogger.com