This website uses cookies. By using this website, you agree to our Cookie Policy.

Read Cookie Policy
DECLINE ALL
NON-ESSENTIAL COOKIES
Accept All Cookies

One CEP to Rule Them All?

March 18, 2026

Cadwalader partner Laura Perkins was quoted in a Corporate Compliance Insights article on the DOJ’s first-ever Department-wide Corporate Enforcement Policy ("CEP") and what it means for companies considering whether to self-report misconduct. The article explains that the new policy is intended to provide a more uniform framework and greater clarity about potential outcomes, but that important questions remain for senior corporate leaders about how the policy will apply in practice.

“As with the previous versions of the CEP, the new CEP moves the needle somewhat because it provides a more uniform framework and gives companies more clarity about the likely range of outcomes, but it does not completely change the analysis,” Laura said. “Even with the benefits offered by the CEP, the decision of whether to self-report remains a complicated one that needs to be carefully evaluated.”

Laura also noted that, in light of the timing and the way DOJ described the new policy’s supersession of other guidance, questions remain about how the CEP interacts with recently announced policies from individual U.S. Attorney’s Offices, including the SDNY. She observed that, because the supersession language appears in DOJ’s announcement rather than in the policy itself, offices may argue that certain features of their own policies continue to describe how they will exercise discretion in areas where the CEP leaves flexibility.

“Overall, compliance officers should not read the CEP as making self-reporting an easy or automatic choice,” Laura said. “The CEP may offer meaningful benefits, but the decision as to whether to self-report still requires a careful, case-specific analysis.”

Read the full article here.

Back to Top