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Compliance Self-Disclosure Requirements Corporate Crimes

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Society of Corporate Compliance and Ethics...

Understanding the DOJ's Recent Corporate Enforcement Policy Changes

On May 12, 2025 the head of the Criminal Division at the US Department of Justice issued a memo to all Criminal Division personnel with the subject: Focus, Fairness and Efficiency in the Fight Against White Collar Crime. To...more

Foley & Lardner LLP

DOJ Criminal Division Updates (Part 3): New Reasons for Companies to Self-Disclose Criminal Conduct

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Share on Twitter Print Share by Email Share Back to top On May 12, 2025, the U.S. Department of Justice (DOJ) announced revisions to its Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP). (See...more

BCLP

DOJ Piles On the Incentives for Individuals to Blow the Whistle on Companies

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Historically, successful white-collar prosecutions often turn on the government’s ability to identify “insiders” with firsthand knowledge of the alleged criminal scheme, who opt to cooperate with prosecutors in exchange for...more

American Conference Institute (ACI)

The DOJ’s New Pilot Programs: A Bane for Compliance Programs

For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more

Mintz

EnforceMintz — DOJ’s Efforts in 2023 to Incentivize Voluntary Self-Disclosure

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2023 was a very active one for Department of Justice (DOJ or the “Department”) guidance, and that guidance had one clear theme: DOJ wants companies to voluntarily self-disclose their misconduct. To incentivize...more

DarrowEverett LLP

How DOJ's Safe Harbor Policy Rewards Honesty Within M&A Deals

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Be you a merger and acquisition attorney, corporate compliance officer, or counsel to an acquiring entity or target entity, you should review the Department of Justice’s new Merger and Acquisition Safe Harbor Policy...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Attorney for SDNY Launches Whistleblower Program To Encourage Self-Disclosure by Individuals

On January 10, 2024, Damian Williams, U.S. Attorney for the Southern District of New York (SDNY), announced the creation of that office’s Whistleblower Pilot Program (Program). This initiative provides notice of the...more

Troutman Pepper Locke

The Stick and the Carrot: DOJ Continues to Eye Corporate Crimes, While Encouraging Prompt Self-Disclosures of Misconduct...

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On October 4, Deputy Attorney General (DAG) Lisa Monaco announced the Department of Justice’s (DOJ) new Safe Harbor Policy for voluntary self-disclosures made in connection with mergers and acquisitions (M&A). This policy is...more

Robinson & Cole LLP

DOJ Announces Extension of Voluntary Self-Disclosure Guidance for Misconduct Discovered Through M&A Due Diligence

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On October 4, 2023, the U.S. Department of Justice (DOJ) announced a uniform approach for the resolution of voluntary self-disclosure (VSD) of misconduct discovered during M&A due diligence. The Mergers & Acquisitions Safe...more

Foley & Lardner LLP

Implications of DOJ’s New Safe Harbor for Disclosing Misconduct Uncovered During M&A Transactions

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U.S. Deputy Attorney General Lisa Monaco recently announced that the Department of Justice (DOJ) is adopting a new safe harbor policy to incentivize corporations to voluntarily self-disclose criminal misconduct discovered...more

Hogan Lovells

DOJ announces policy for self-disclosures on criminal misconduct of acquired companies, with a catch

Hogan Lovells on

Deputy Attorney General Lisa Monaco announces a new safe harbor policy for voluntary self-disclosures of acquired entities’ criminal misconduct. Although the new safe harbor provides clear timelines for disclosure, the costs...more

Guidepost Solutions LLC

U.S. Attorneys’ Offices Voluntary Self-Disclosure Policy - Watch Out for The Next Logical Step – Enforcement

It is safe to assume that the United States Attorneys’ Offices Voluntary Self-Disclosure Policy announced on March 2, 2023 is intended to decrease wrongdoing and impose rehabilitation and recovery for victims. But...more

King & Spalding

DOJ Corporate Enforcement Policy Revisions Target Executive Compensation, Following Multi-Agency Trend

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On March 2, 2023 and March 3, 2023, in a pair of speeches by Deputy Attorney General (DAG) Lisa Monaco and Criminal Division Assistant Attorney General (AAG) Kenneth Polite, the U.S. Department of Justice (DOJ) announced...more

Harris Beach Murtha PLLC

Biden Department of Justice Implements New Corporate Voluntary Self-Disclosure Policy for Criminal Investigations

United States Attorney’s Offices across the country have announced the implementation of a new Voluntary Self-Disclosure Policy to standardize how voluntary self-disclosure (VSD) of misconduct is defined and credited by USAOs...more

McDermott Will & Emery

DOJ Announces Major Changes to Corporate Compliance Program Evaluation Criteria

During speeches on March 2 and 3, 2023, at the American Bar Association (ABA) National Institute on White Collar Crime (the 2023 White Collar Conference), Deputy Attorney General (DAG) Lisa Monaco, Assistant Attorney General...more

BakerHostetler

DOJ Announces Major Corporate Enforcement Policies

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Monaco’s and Polite’s remarks, and the DOJ’s new policies and guidance, come amid the Department’s increasingly tough on corporate crime approach and emphasis on rewarding companies that have effective compliance programs...more

Goodwin

DOJ Announces Nationwide Voluntary Corporate Self-Disclosure Policy in Effort to Standardize and Incentivize Timely Self-Reporting

Goodwin on

On February 22, 2023, the US Department of Justice (DOJ) announced a Voluntary Self-Disclosure Policy (VSD Policy) to formalize DOJ’s efforts to incentivize companies to voluntarily self-report criminal misconduct to the...more

Ankura

Key Compliance Takeaways from DOJ Memorandum

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“Further Revisions to Corporate Criminal Enforcement Policies Following Discussions with Corporate Crime Advisory Group” - Compliance programs play a critical role for healthcare organizations, ensuring both individuals...more

Snell & Wilmer

DOJ Revisits its Corporate Criminal Enforcement Policy Offering Companies Additional Incentives to Self-Disclose, Cooperate, and...

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On January 17, 2023, Assistant Attorney General (“AAG”) Kevin Polite announced revisions to the Department of Justice’s (“DOJ”) Corporate Enforcement Policy (“CEP”), which will apply to all corporate criminal matters. The...more

McGuireWoods LLP

New Incentives Added to the Criminal Division’s Corporate Enforcement Policy

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On January 17, 2023, Assistant Attorney General (AAG) Kenneth A. Polite, Jr. delivered remarks to an audience at the Georgetown University Law Center, announcing changes to the Criminal Division’s Corporate Enforcement Policy...more

Lowenstein Sandler LLP

DOJ Revamps Incentives for Companies to ‘Come Forward, Cooperate, and Remediate’

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On January 17, 2023, the Department of Justice (DOJ), Criminal Division, announced it has reassessed and strengthened its Corporate Enforcement Policy, which applies to all corporate criminal matters (including Foreign...more

Ankura

DAG Monaco Defines DOJ Guidance for Corporate Criminal Enforcement

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New Requirements Place Onus on Corporations to Demonstrate more Compliance Capabilities to Receive Consideration from Prosecutors On September 15, 2022, Deputy Attorney General (“DAG”) Lisa Monaco spoke at New York...more

Seward & Kissel LLP

DOJ’s Revised Corporate Criminal Enforcement Policies Encourage Voluntary Disclosure and Focus on Compensation

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On September 15, 2022, Deputy Attorney General Lisa O. Monaco announced new Department of Justice (“DOJ”) policies on corporate criminal enforcement. DOJ designed the new policies based on recommendations by the Corporate...more

Foley & Lardner LLP

DOJ’s New Corporate Enforcement Policies Target Individuals and Incentivize Self-Disclosure

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On September 15, 2022, Deputy Attorney General Lisa Monaco announced significant changes to the U.S. Department of Justice’s (DOJ) approach to corporate criminal enforcement, including revised policies and an accompanying...more

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