To Disclose or Not to Disclose: DOJ Revises Its Policy on How Corporate Criminal Matters Are Handled in an Attempt to Further Incentivize Voluntary Disclosure and Cooperation

In response to a recent DOJ request that all its components write voluntary self-disclosure policies and “clarify the benefits of promptly coming forward to self-report [as] a good business decision,” the Criminal Division updated its Corporate Enforcement and Voluntary Self-Disclosure Policy.