Partner Sandra Moser was quoted in a Global Investigations Review article discussing the Department of Justice’s declination letter announcing its decision not to prosecute Liberty Mutual after evidence of bribery by its India subsidiary was revealed, because the company voluntarily reported the misconduct, cooperated with the government, and improved compliance.
Sandra noted that unlike a plea agreement, a declination letter, while containing high-level information about the factors considered to reach the resolution, doesn’t necessarily reveal details about the investigation or the compliance changes a company made.
“I don’t think this one, which sort of is in a vacuum, really holds back the curtain,” Sandra said. “Now that we have the Liberty Mutual resolution, you’re going to need a counterpoint,” she added.