The Department of Justice announced, in January, new revisions to its corporate enforcement policy related to voluntary self-disclosure, cooperation, and remediation. The revisions were designed to incentivize companies that become aware of misconduct to engage proactively with law enforcement and strengthen their compliance programs.
In an article written for Bloomberg Law, litigation and enforcement partner Geoffrey Atkins and associate Rory Skowron provided insights into the revisions to the DOJ’s voluntary self-disclosure policy and key takeaways for companies.
“The decision to self-report remains a complex and difficult one that should only be undertaken on a case-by-case basis after serious consideration and consultation with counsel,” said Geoff. “Albemarle’s settlement illustrates the consequences of delayed disclosure and potential benefits, once a decision to self-report has been made, of doing so as promptly as feasible.”
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