Another Declination from DOJ’s Criminal Division Emphasizes the Continued Focus on Voluntary Self-Disclosure in 2024

Drawing on a carrot and stick approach, Department of Justice (“DOJ” or the “Department”) guidance in 2023 focused heavily on incentivizing companies to voluntarily self-disclose their misconduct. This guidance included the Criminal Division’s revised Corporate Enforcement Policy (the “CEP”), the United States Attorneys’ Offices Voluntary Self-Disclosure Policy (the “VSD Policy”), and the Safe Harbor Policy for voluntary self-disclosures made in connection with mergers and acquisitions (the...
By: Mintz

Array