То есть против компаний, которые сами на себя донесут в Министерство юстиции, не будут возбуждаться судебные дела, и им даже уменьшат штрафы.

https://www.dlapiper.com/en/us/insights/publications/2016/10...

In an aggressive effort to encourage companies to self-report putative violations of the FCPA, the Department of Justice has been touting several recent decisions to decline prosecutions ("declinations") based on the self-reporting companies’ full cooperation and disgorgement of all profits attributable to the illicit payments. While clearly part of a marketing effort to push the benefits available under the FCPA Pilot Program launched in April 2016, these resolutions provide additional guidance to companies and compliance professionals as to the kinds of investigation and remediation DOJ and SEC have come to expect. They also provide some data points that can assist in the ongoing struggle to determine when self-reporting is in a company’s interest.

This spring, the Department of Justice announced a one-year Pilot Program intended to incentivize companies to self-report FCPA violations and encourage cooperation with investigations. Pursuant to that program, companies that self-report and cooperate are, in certain circumstances, eligible for declinations and/or reductions in fines. Such companies can also avoid the appointment of a monitor. At the end of the one-year FCPA Pilot Program, the DOJ will determine whether or not to extend it.