Compliance Stuff

On March 10, 2026, the U.S. Department of Justice released an updated Corporate Enforcement and Voluntary Self-Disclosure Policy (the “DOJ CEP”) 1 , which for the first time in the Department’s history will cover most corporate criminal matters . The policy builds upon revisions released in May 2025 (which “traces its roots to 2016” according to Department leadership) 2  with the stated goal to further incentivize companies to promptly report misconduct, cooperate with government investigations, and remediate wrongdoing , while providing clearer and more predictable outcomes for companies that do so. The DOJ CEP reflects the Department’s continued emphasis on early disclosure, individual accountability, and strong corporate compliance programs as key components of effective enforcement. Under the revised policy, companies that voluntarily self-disclose misconduct, fully cooperate with Department, and timely and appropriately remediate the misconduct themselves  will generall...

The Justice Department has announced new, more relaxed policies for when it will prosecute corporate crime, promising “a clear path to declination” that bypasses the criminal resolution process entirely for companies that self-disclose and remediate their misconduct.   Matthew Galeotti , acting head of the Criminal Division at the Justice Department,  announced the new policy in a speech he delivered Monday . In many ways the new policy follows previous corporate enforcement policy under the Biden Administration, with an emphasis on voluntary self-disclosure, cooperation with prosecutors, and timely remediation of the offenses.  This new policy goes even further, however, clearly states that companies meeting all three criteria  will  receive a declination, not just the “presumption of a declination” standard that had existed previously.  Galeotti “ Those companies that meet our core requirements — voluntarily self-disclose to the Criminal Division, fully c...