DOJ's New Corporate Enforcement Policy: Self-Disclosure Pays Off in 2026

Welcome back, listeners, to your weekly DOJ dispatch. This week's blockbuster: On March 10, the Department of Justice unveiled its first-ever department-wide Corporate Enforcement Policy for criminal cases, excluding antitrust. As Deputy Attorney General Todd Blanche put it, "This Department of Justice is committed to transparency and fairness... Well-intentioned businesses know that, across the Department, they will be rewarded when they self-disclose wrongdoing, cooperate with our investigations, and remediate the misconduct." Kirkland and Ellis reports this policy supersedes all prior component-specific rules, promising declinations for companies that voluntarily disclose misconduct promptly, fully cooperate, and remediate—unless aggravating factors like severe harm or recidivism apply. Building on the Criminal Division's May 2025 updates under then-head Matthew Galeotti, which emphasized "focus, fairness, and efficiency," this CEP standardizes white-collar prosecutions. It guarantees no charges in qualifying cases, with "near miss" non-prosecution deals for close calls. DOJ's Fraud Section notched 15 corporate actions in 2025 alone, per their Year in Review. Earlier this year, on January 8, President Trump launched the new Division for National Fraud Enforcement to tackle fraud against federal programs and citizens. The White House notes it's already issued 1,750 subpoenas and charged 13 defendants from one probed facility. Antitrust struck too: On March 26, DOJ sued New York-Presbyterian Hospital for restrictive insurer contracts blocking affordable health plans, per Concurrences. For American citizens, this means stronger shields against corporate fraud and white-collar crimes draining public funds—think safer benefits and fairer healthcare pricing. Businesses face clear incentives to self-report, cutting compliance costs and risks, but tougher scrutiny on insiders, with over 200 charged last year. States and locals benefit from uniform enforcement aiding joint probes, while international ties sharpen via prioritized FCPA cases tied to national security. Experts like Assistant AG A. Tysen Duva hail it as rooting out sophisticated schemes. Watch for rising declinations and individual prosecutions in 2026. Stay tuned to justice.gov for updates, and if your company spots issues, consider self-disclosure now. Next week: Fraud Division's first big wins. Thanks for tuning in, listeners—subscribe for more. This has been a Quiet Please production, for more check out quietplease.ai. For more http://www.quietplease.ai Get the best deals https://amzn.to/3ODvOta This content was created in partnership and with the help of Artificial Intelligence AI.