DOJ Announces Department-Wide Corporate Self-Disclosure Program

New policy aims to standardize how prosecutors evaluate voluntary self-disclosure, cooperation, and remediation.

Mar. 17, 2026 at 1:19am

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The U.S. Department of Justice (DOJ) has announced a new department-wide Corporate Enforcement Policy (CEP) that will replace prior component and district programs, including the recent policy unveiled by the U.S. Attorney's Office for the Southern District of New York. The new CEP closely tracks the DOJ Criminal Division's existing Corporate Enforcement and Voluntary Self-Disclosure Policy, offering incentives for companies that promptly self-disclose misconduct, fully cooperate, and undertake timely remediation.

Why it matters

The DOJ's new unified corporate enforcement policy is likely to drive increased disclosure and enforcement activity by reducing uncertainty around the availability and contours of cooperation credit. This adds urgency for companies to invest in proactive compliance programs to quickly identify potential misconduct and meet the policy's requirements for the greatest benefits.

The details

The new CEP offers three categories of potential benefits to companies: declination of prosecution, a 'near-miss' resolution with a non-prosecution agreement and reduced fines, or limited mitigation with up to a 50% reduction in fines. The policy shifts from the Criminal Division's prior fixed 75% reduction framework to provide prosecutors more flexibility in determining fine reductions. It also expands the avenues for voluntary self-disclosure beyond just the Criminal Division.

  • The DOJ announced the new department-wide CEP on March 10, 2026.
  • The policy supersedes all prior component-specific and U.S. Attorney's Office-specific corporate enforcement policies, other than those applicable to DOJ antitrust enforcement.

The players

U.S. Department of Justice (DOJ)

The federal executive department responsible for the enforcement of the law and administration of justice in the United States.

Todd Blanche

Deputy Attorney General at the U.S. Department of Justice.

U.S. Attorney's Office for the Southern District of New York

The U.S. Attorney's Office that recently unveiled its own 'Corporate Enforcement and Voluntary Self-Disclosure Program for Financial Crimes', which has now been superseded by the new DOJ-wide policy.

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What’s next

Companies should be prepared to quickly identify potential misconduct and ensure their compliance programs are effective, as the greatest benefits under the new DOJ-wide CEP are only available when misconduct is promptly reported and remediated.

The takeaway

The DOJ's new unified corporate enforcement policy aims to bring greater uniformity, predictability, and transparency to how prosecutors evaluate self-disclosure, cooperation, and remediation, incentivizing companies to invest in robust compliance programs to quickly identify and address potential misconduct.