DOJ Corporate Enforcement and Voluntary Self-Disclosure Policy
Summary
The Department of Justice has updated its Corporate Enforcement and Voluntary Self-Disclosure Policy, effective March 10, 2026. This policy outlines the DOJ's approach to corporate criminal enforcement and provides incentives for companies that self-disclose misconduct.
What changed
The Department of Justice's Antitrust Division has updated its Corporate Enforcement and Voluntary Self-Disclosure Policy, with the latest version dated March 10, 2026. This policy details the department's approach to prosecuting corporate crime, emphasizing the benefits of voluntary self-disclosure, full cooperation, and timely remediation. Key aspects include potential declinations, reduced penalties, and specific criteria for qualifying for these benefits.
Companies operating in the US, particularly those in industries subject to antitrust scrutiny or with potential for corporate misconduct, should review the updated policy. It is crucial to understand the requirements for voluntary self-disclosure, cooperation, and remediation to potentially mitigate penalties in the event of a violation. While the policy is non-binding, adherence can significantly impact the outcome of DOJ investigations and enforcement actions.
What to do next
- Review the updated DOJ Corporate Enforcement and Voluntary Self-Disclosure Policy.
- Assess current internal compliance programs against the policy's requirements for self-disclosure, cooperation, and remediation.
- Ensure relevant personnel are trained on the policy's implications for corporate conduct.
Source document (simplified)
### MENU Foreign Corrupt Practices Act Unit
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| Department of Justice Corporate Enforcement and Voluntary Self-Disclosure Policy (March 2026) |
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Updated March 10, 2026
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