Brass Tacks: Would You Call the Government to Make a Disclosure Today? If So, Why?

At the 2025 TRACE Annapolis Forum, Chuck Duross, Global Co-Chair of the FCPA and Global Anti-Corruption Practice at Morrison Foerster, discusses the DOJ’s evolving voluntary self-disclosure policies and the balance of risks and rewards for companies. From increased incentives under the 2025 Corporate Enforcement Policy to the challenges of parallel investigations, Charles explores what drives the decision to self-disclose and why it remains one of the toughest calls in compliance today.

At the 2025 TRACE Annapolis Forum, Billy Jacobson, Partner at Jacobson Lopez, explores the DOJ’s shifting FCPA priorities—from a focus on “grand corruption” and the costs of investigations to prosecutorial uncertainty and statutes of limitation. In today’s unpredictable environment, companies must stay the course, protect resources, and invest in training.

At the 2025 TRACE Annapolis Forum, Nicola Bonucci, Associate Professor at Paris Cité and former General Counsel of the OECD, reflects on 25 years of the OECD Anti-Bribery Convention and the evolving challenges of global enforcement. From uncertainties around FCPA guidance, political influence, and uneven implementation, to questions about the U.S.’s continued leadership in anti-bribery efforts, Nicola highlights the risks companies face in an increasingly unpredictable landscape—where cross-border investigations, bribe solicitation, and public scrutiny are on the rise.

Speaking at the 2022 TRACE London Forum, Oliver Bullough, author of Butler to the World, discusses the UK’s role as an enabler of financial crime, efforts toward accountability, the balance between transparency and privacy, and the weaponization of lawsuits in British courts to silence journalists.   This episode was originally published on 26 October 2022.  

This is a powerful session from the 2022 TRACE London Forum featuring Leonid Volkov, former Chief of Staff to Alexei Navalny and Political Director of the Anti-Corruption Foundation (ACF). Leonid discusses the role of corruption in Putin’s Russia as well as the impact of sanctions and the toll that rampant corruption is taking on Russia.   This episode was originally published on 5 October 2022.

Eugene Soltes, Author, and Professor of Business Administration at Harvard Business School, describes his fascinating research into what motivates white collar criminals and how distance from their victims makes it easier.   This episode was originally published on 30 August 2017.

Karen Benson, Senior Counsel, Legal, at Energizer Holdings, shares a broad range of tips on how to build a targeted, innovative training program that keeps employs interested and engaged.   This episode was originally published on 15 May 2019.

This week’s podcast features an excellent presentation by Misti Mukherjee, founder and managing member of Extensio Law.  Misti addresses the shifting field of diversity, equity and inclusion—including recent changes to the law—and emphasizes the critical importance of this work alongside the need to approach it with intentionality and discipline.   This episode was originally published on 5 August 2024.

Chuck Duross, Global Co-Chair of the FCPA and Global Anti-Corruption Practice at Morrison Foerster, and former head of the DOJ’s FCPA unit, discusses lures, stings, wiretaps and INTERPOL Red Notices.   This episode was originally published on 7 March 2018.

Nick McKenzie, award-winning Australian investigative journalist, shares the inside story of his role in exposing the Unaoil scandal.   This episode was originally published on 12 July 2017.