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On March 10, the US Department of Justice (DOJ) announced its Corporate Enforcement and Voluntary Self-Disclosure Policy (the Department CEP), a first-of-its-kind uniform corporate enforcement policy. While it is similar to the prior policy issued by the Criminal Division, last revised in May of 2025 (the Criminal Division CEP), the Department CEP introduces key changes, including modifications to the resolution framework and other policy shifts relating to self-disclosure requirements, cooperation standards, and credit, and the Corporate Whistleblower Awards Pilot Program.
The Department CEP governs all corporate criminal matters resolved with the DOJ, except for criminal antitrust matters, and "supersed[es] all component-specific or U.S. Attorney's Office-specific corporate enforcement policies currently in effect." Like prior CEPs, the Department CEP's purpose is to incentivize companies to voluntarily self-disclose misconduct, cooperate with investigations, and remediate wrongdoing.
All corporate resolutions must be approved by the relevant Assistant Attorney General or US Attorney in coordination with the Office of the Deputy Attorney General and the Criminal Division, as required by the Justice Manual. Like the Criminal Division CEP, the Department CEP is divided into three parts to describe various outcomes if a company self-reports: (1) declinations, (2) "near miss" voluntary self-disclosures, and (3) other resolutions. It also includes a similar flowchart illustrating the possible outcomes based on key factors.
Read more about the Department CEP and its practical implications in our detailed alert.
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