Beveridge & Diamond
 

Pete Anderson Authors Article on Disclosures in Compliance & Ethics Professional

March 29, 2016

Pete Anderson, a Principal in Beveridge & Diamond’s Washington, DC office and leader of the firm’s White Collar and Environmental Crimes practice group, authored an article in the April 2016 issue of Compliance & Ethics Professional, a publication of the Society of Corporate Compliance and Ethics, titled “To disclose, or not to disclose? That is often a tough question.”

Mr. Anderson discusses the practical considerations that arise when deciding whether various instances of misconduct need to be disclosed to governmental authorities.  He notes that once corrective measures are taken and the cause of the misconduct is understood, the next question is whether to alert the regulators. 

Mr. Anderson addresses the following factors that often influence the decisions surrounding disclosures:

  • Whether the violations are historical or on-going
  • Whether the disclosures are mandatory or voluntary
  • If voluntary, what factors should be considered
  • The likelihood of detection if you choose to not disclose, and the consequences if caught without disclosing
  • The seriousness of the violations
  • The benefits that accompany voluntary disclosure
  • If you choose to disclose, what are the most important factors
  • If you do not disclose, what else should we do or prepare for

Read the full article.

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