On February 22, 2023, the U.S. Department of Justice ("DOJ" or "Department") announced the Voluntary Self-Disclosure Policy ("VSD Policy" or "Policy"), detailing the circumstances under which a company can receive credit for voluntarily self-disclosing criminal conduct to U.S. Attorneys' Offices ("USAOs"). This represents a shift in corporate enforcement at the USAOs, which had generally lacked formal policies for self-disclosure credit and applied varying and nontransparent approaches on an office-by-office basis.
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