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ARTICLE · 26 JANUARY 2026

Streamlined DOJ Resolutions: Declinations, NPAs, And DPAs Explained — EnforceMintz

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
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Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

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Department of Justice (DOJ)'s revised Corporate Enforcement Policy (May 2025) expands incentives for voluntary self-disclosure and clarifies pathways to NPAs and DPAs — critical for companies facing enforcement risk.

United StatesCorporate/Commercial Law

Department of Justice (DOJ)'s revised Corporate Enforcement Policy (May 2025) expands incentives for voluntary self-disclosure and clarifies pathways to NPAs and DPAs — critical for companies facing enforcement risk.

KEY POINTS:

  • Expanded voluntary self-disclosure policy creates opportunities. DOJ's revised Corporate Enforcement Policy offers a clear path to declinations for companies that voluntarily self-disclose misconduct, cooperate fully, and remediate promptly.
  • NPAs and DPAs are increasingly accessible. Even when voluntary self-disclosure criteria are not met, companies demonstrating cooperation and remediation may secure non-prosecution agreements or deferred prosecution agreements, often with favorable terms such as reduced penalties and no compliance monitors.

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