Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors.

In a speech at Georgetown University Law Center on January 17, 2023, Assistant Attorney General Kenneth Polite (AAG Polite) announced revisions to the US Department of Justice (DOJ) Criminal Division’s Corporate Enforcement Policy (CEP). The revisions, the most significant since 2017, are primarily designed to incentivize companies to invest significantly in compliance, come forward at the earliest point when they discover corporate misconduct, and fully cooperate with DOJ investigations.