The DOJ Announces Administration's Revised Corporate Enforcement Strategy

Key Takeaways

• The DOJ announced a revised corporate enforcement strategy that aligns with the Administration's priorities in areas such as national security, trade and customs offenses, fraud in U.S. markets and government programs, narcotics trafficking and terrorism, and it also revised certain previously issued policies to make them consistent with the Administration's priorities. This includes prosecutions to protect U.S. businesses and American economic competitiveness from unfair practices such as foreign bribery, money laundering, and theft of U.S. trade secrets/practices/technology.

• The DOJ will continue to incentivize corporate voluntary self-disclosures and has revised its Corporate Enforcement and Voluntary Disclosure Policy to clarify the benefits that will inure to companies that voluntarily and timely self-report, including a commitment to decline prosecution for companies self-disclosing misconduct without aggravating circumstances and that