Dutch Public Prosecution Office Publishes Rules On Self-Disclosure, Cooperation And Self-Investigation

The Dutch Public Prosecution Office ("DPPO") has introduced a new policy (aanwijzing), effective 1 January 2025, outlining conditions and fine reductions for self-disclosure, cooperation and self-investigation in corporate criminal investigations.

On 22 November 2024, the DPPO issued its "Policy on Self-Disclosure, Cooperation and Self-Investigation" (the "Policy"). The Policy provides a long-awaited framework on whether and when self-disclosure and cooperation in criminal investigations can result in a reduction of fines. The Policy aims to encourage transparency and accountability by offering incentives for proactive engagement. Entities that voluntarily, comprehensively and timely disclose potential criminal offenses and fully cooperate in criminal investigations may be eligible for a reduction in fines of up to a total of 50%. The Policy will take effect on 1 January 2025.