Companies today face a critical crossroads when internal whistleblowers report potential misconduct. The Department of Justice's revised enforcement policies have created powerful—and competing—incentives that make swift, decisive action on internal complaints more important than ever. While the DOJ offers unprecedented benefits to companies that voluntarily self-disclose criminal or civil violations, it simultaneously provides whistleblowers with substantial financial rewards for reporting directly to the government. This tension, combined with the realities of shifting enforcement priorities across administrations, demands that corporate compliance leaders and their counsel act with both urgency and strategic sophistication.
In May 2025, Assistant Attorney General Matthew Galeotti fundamentally reshaped the DOJ's approach to corporate enforcement through his memorandum, Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime. The revised Corporate Enforcement Policy (CEP) announced in the memo represents a sea change: companies that voluntarily self-disclose, cooperate fully, and remediate effectively now receive declinations (no prosecution) as a matter of course, not merely as a presumption. As Galeotti emphasized in his June 2025 remarks at the American Conference Institute, "I am standing behind this policy" and will "closely scrutinize any VSD (voluntary self-disclosure) that is not recommended for...
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