• The DOJ will not prosecute companies when they voluntarily self-disclose misconduct, fully cooperate with the DOJ’s investigation, and correct the misconduct in a timely and appropriate manner.
• Companies will be eligible for a declination even if a whistleblower reports to the DOJ first, if the company self-reports to DOJ within 120 days of receiving an internal report.
• The new policy became effective immediately.

The DOJ investigates a wide range of corporate crimes, including financial fraud, identity theft, insider trading, foreign bribery, money laundering, sanctions evasions, government benefit fraud, and healthcare kickback schemes. The new enforcement policy applies to all types of corporate criminal cases, except those relating to antitrust matters. It applies to companies in all industries, including financial services.

To receive a declination (or decision to not prosecute), a company must:

• promptly self-report conduct previously unknown to the DOJ,
• self-report before an imminent threat that DOJ would discover the misconduct,
• have no previous obligation to self-report to the DOJ,
• fully cooperate with investigators, and
• promptly correct violations.

If a whistleblower reports wrongdoing both internally and to the DOJ, the company will still be exempt from prosecution if the company self-reports to the DOJ within 120 days after receiving the whistleblower’s internal report.

If a company fully cooperated and timely remediated misconduct, but it is ineligible for...

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