Voluntary Disclosure In 2026: Risk, Reward, And Uncertainty

Tom Fox

We take a look at what the DOJ is currently saying about self-disclosure and ask has the bar moved far enough now that you could recommend it.

Dr. Hemma Lomax

I've really enjoyed coming to the ACI conference for decade there over a decade now. I started my career in the US at least at the SEC and I was there for 11 years seeing some of these voluntary disclosures coming from the other side and working in parallel investigations with the DOJ. And then since then I left around 2020 to go into in-house roles at Disney, Snapchat, Zendesk and I sign. And if I may I'll just say this is such an interesting topic. I've seen a lot of this coming in from the outside. I must say that I don't speak obviously on behalf of the SEC. It's been a while since I've been there and also I don't speak on behalf of or the other places I've worked for. I'm fortunate not to have to dealt with too many voluntary disclosure matters from this side of the house and that's why I am free to talk today.

Dr. Hemma Lomax

I've really enjoyed coming to the ACI conference for decade there over a decade now. I started my career in the US at least at the SEC and I was there for 11 years seeing some of these voluntary disclosures coming from the other side and working in parallel investigations with the DOJ. And then since then I left around 2020 to go into in-house roles at Disney, Snapchat, Zendesk and I sign. And if I may I'll just say this is such an interesting topic. I've seen a lot of this coming in from the outside. I must say that I don't speak obviously on behalf of the SEC. It's been a while since I've been there and also I don't speak on behalf of or the other places I've worked for. I'm fortunate not to have to dealt with too many voluntary disclosure matters from this side of the house and that's why I am free to talk today.

Daniel Sibille

today I serve as the compliance officer for the region, Latin America, so I've been working on Oracle over the last 15 years.

Daniel Sibille

We see at least two panels with a lot of Brazilians, authorities, so it's nice to see how the compliance framework evoluted over the years.