New DOJ Corporate Enforcement Policy
On March 10, 2026, the U.S. Department of Justice (“DOJ” or “Department”) issued a press release announcing its “first-ever” Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (the “CEP”). The CEP is an explicit attempt to harmonize prior corporate enforcement and self-disclosure standards across DOJ and the U.S. Attorneys’ Offices, except the Antitrust Division.
Companies interested in taking advantage of the CEP must:
- Voluntarily disclose discovered misconduct to the appropriate criminal component of the DOJ;
- Cooperate fully with any resulting DOJ investigations; and
- Timely and appropriately remediate the wrongdoing.
The benefits for a company that voluntarily discloses, and has no “aggravating factors,” include:
- A presumption of declination for the disclosing party;
- Avoidance of a corporate monitor; and
- Shorter compliance reporting terms.