Commercial Dispute Resolution | Quarterly Focus: Self-disclosure in the new age of DOJ declinations
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In an article for Commercial Dispute Resolution, Global White Collar and Investigations Practice Chair Joel Cohen discussed the US Department of Justice's expanded Corporate Enforcement Policy and its use of declinations to encourage corporate self-disclosure.
Joel noted that recent declinations provide tangible evidence that companies may obtain a full declination if they report misconduct early and meet the policy's requirements. He cautioned, however, that companies must weigh the uncertainty of the outcome because disclosure gives the government knowledge of the issue even if a declination is not ultimately available.
Read the full article here.
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