O’Melveny Partners Cheng and Guo Quoted in The FCPA Report on Recent Settlement

February 24, 2016

The February 24, 2015, FCPA Report detailed a recent US$28 million settlement that PTC Inc. paid to settle civil and criminal Foreign Corrupt Practices Act violations. The article quotes Beijing O’Melveny partner Bingna Guo saying, “the PTC settlement shows that incomplete or partial self-disclosures are not enough to obtain a declination.” The article goes on to quote Los Angeles and Hong Kong partner Ron Cheng saying the settlement also highlights a dilemma that many companies have when investigating potential corruption, prompting a company “to report at the completion of its investigation, for fear that early disclosure of what it knows at the outset of its investigation may be deemed inadequate because of other facts that the regulators later assert the company knew about.”