The Department of Justice (DOJ) has released an update to its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP). The update expands the policy to the entire department, the first ever unified framework governing corporate criminal enforcement across all DOJ components. The updated policy applies to all corporate criminal matters handled by the DOJ, with the sole exception of antitrust violations. For compliance teams, it removes uncertainties about which policy applies when a disclosure implicates multiple components and whether different offices produce uneven outcomes.
One policy across all departments
Announced on March 10, 2026, the update extends the framework first introduced in May 2025 to every component and all 93 U.S. Attorney’s Offices nationwide. It supersedes the patchwork of component and district-specific self-disclosure policies that previously left companies guessing.
There are two major updates for compliance teams:
- Reporting is now channel-neutral: A company can self-disclose to any appropriate DOJ component, and that good-faith disclosure is still recognized if another component takes over the case.
- The benefit for “near miss” disclosures is reduced: The 2025 policy offered a fixed 75% reduction off the low end of the Sentencing Guidelines; the 2026 policy sets a range of 50%-75% at prosecutors’ discretion.
Disclosing earlier and cooperating fully still moves the needle for companies aiming to get ahead of an audit or whistleblower. Last year, the DOJ released a flowchart showing these three paths to favorable resolution. We’ve updated that flowchart to reflect the latest policy change and show how proactive compliance monitoring can help you achieve one of those three resolutions.
