Corporate Enforcement Policy

The DOJ reached the agreement with the company under its 2026 Corporate Enforcement and Voluntary Self-Disclosure Policy or CEP.

For compliance professionals attending the annual conference, the takeaway was hard to miss: 2026 will require a more rigorous compliance framework and transparency.

The new policy supersedes the existing patchwork of voluntary self-disclosure policies, replacing them with a framework applicable across the DOJ.

SDNY said after a company self-reports, it will issue a conditional letter stating intent to decline prosecution, if certain criteria are met.

Millicom received a 50% discount on the possible criminal penalty it was facing, thanks to its extensive cooperation and remediation efforts.

Moser and Pease talk about a corporate enforcement and voluntary self-disclosure policy that has seen a variety of iterations through several administrations.

Julie DiMauro spoke to the founder and CEO of Integrity Bridge, and former Chief Risk & Compliance Officer of Albemarle Corporation.

Citing a need for transparency in the DOJ’s corporate criminal enforcement efforts, Deputy AG Argentieri outlined some tweaks to the agency’s Corporate Enforcement Policy.