Falling on the Sword in the Name of Cooperation: Executive Resigns and Company Self-Reports FCPA Investigation Results to SEC and DOJ

Model corporate citizen J&J announced the resignation one of its senior executives, who stepped down upon a voluntarily disclosure to the SEC and Department of Justice the results of an investigation showing improper payments to foreign officials. Time will tell whether a high-level “resignation” and self reporting will affect charge decisions. The case also raises interesting questions around selective waiver, currently subject of debate in the context of proposed new Federal Evidence Rule 502(c), assuming J&J decides to hand over interview summaries or more than simply the outcome of the investigation.

For more on the story, see Wall Street Online Journal.

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