Gibson Dunn Lawyers Author Chapter on Self-Reporting for GRR’s The Practitioner’s Guide to Global Investigations

Article  |  November 5, 2026

Global Investigations Review

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Partners Stephanie Brooker, Matthew Axelrod, and David Ware, of counsel Abby Dugan, and associate Allison Frison are the authors of the chapter “Self-Reporting to the Authorities and Other Disclosure Obligations: The US Perspective” for the 11th edition of Global Investigations Review’s The Practitioner’s Guide to Global Investigations.

The authors describe the wide variety of considerations involved in a corporation’s decision to voluntarily self-disclose potential misconduct to the DOJ or other regulators. “Corporate decision makers must weigh the benefits of self-reporting … against the risks attendant to reporting such misconduct,” they write, “often in the face of uncertainty.”  The authors add: “These decisions are inherently fact- and circumstance-specific, and should be carefully considered in light of the evolving guidance provided by US enforcement agencies.”