Today’s Star Ledger reports on Tyco International’s disclosure to regulators that it hired outside counsel to review whether one of its business units violated the Foreign Corrupt Practices Act by making improper payments to foreign officials. The Foreign Corrupt Practices Act has a self reporting provision which requires companies to act as their own monitor and alert regulators when perceived improper practices are discovered. In this particular case, Tyco reported the results of its review to the Justice Department and the Securities and Exchange Commission.
This situation is a good example of a circumstance where it is important for an organization to bring in independent counsel who can objectively investigate alleged infractions.