DOJ’s New CEP Offers Guaranteed Declination for Some Self-Reporters - corporatecomplianceinsights.com
(Breaking news; last updated at 12:30 p.m. ET May 13)
The Trump Administration continues reshaping its approach to corporate crime, with the DOJ issuing major revisions of its corporate enforcement policy. Changes establish guaranteed declination paths for qualifying self-reporters, revise focus for the department’s whistleblower program and seek to massively curtail the use of corporate monitorships.
The DOJ has moved to further formalize the Trump Administration’s pivot on corporate crime, revising the Criminal Division’s corporate enforcement policy (CEP), restricting monitorships and outlining clearer paths for companies to avoid prosecution.
Revised policies establish three distinct resolution paths, with companies that voluntarily self-disclose misconduct receiving a guaranteed declination rather than just a presumption if they meet certain other qualifications, while simultaneously repositioning the DOJ’s whistleblower program to prioritize tips on tariff fraud, violations of immigration law and cases involving cartels and terrorist organizations. The focus on cartels and terrorism reflect changes made earlier this year, when Attorney General Pam Bondi issued orders pausing FCPA enforcement and redirecting resources toward combating cartels and transnational criminal organizations (TCOs).
Speaking at a May 12 conference on financial crimes and AML, Matthew R. Galeotti, head of the DOJ’s Criminal Division, said the changes were designed to eliminate burdensome...
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