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May 14, 2025
Cadwalader partner Gina Castellano spoke with Corporate Compliance Insights about the United States Department of Justice’s (DOJ) recent changes to its Corporate Enforcement Policy (CEP).
Gina noted that while the updated policy offers a guaranteed declination for companies that meet all self-disclosure requirements, the DOJ’s determination of whether a disclosure is “reasonably prompt” is outside of companies’ control.
She also highlighted the new “near-miss category,” which allows for non-prosecution and no monitor, even if a company does not fully meet the voluntary self-disclosure criteria, could factor into a company’s decision to self-disclose.
Read the full article here.
