Legal Alerts/Details

DOJ Incentivizes Voluntary Self-Disclosure of Corporate Criminal Misconduct in Policy Directive to U.S. Attorneys’ Offices Nationwide

March 06, 2023
  1. See “Damian Williams and Breon Peace Announce New Voluntary Self-Disclosure Policy for United States Attorney’s Offices (hereinafter “Press Release”),” (Feb. 22, 2023), available at; “United States Attorneys’ Offices Voluntary Self-Disclosure Policy (hereinafter “Text of Policy”),” (last visited March 6, 2023), available at

  2. See Press Release and Text of Policy.

  3. Text of Policy at 3 & n.6.

  4. Id. at 3.

  5. Id. at 4.

  6. Id.

  7. Id.

  8. Id. (citing Justice Manual § 9-28.700).

  9. See Text of Policy at 3.

  10. Id. at 4.

  11. Id. at 4 & n.7, and at 5.

  12. Id. at 5.

  13. Id. at 4 & n.7; see, e.g., Memorandum from Deputy Attorney General Lisa O. Monaco, “Further Revisions to Corporate Criminal Enforcement Policies Following Discussions with Corporate Crime Advisory Group (hereinafter “Monaco Memo”),” (Sep. 15, 2022), available at, and Memorandum from Deputy Attorney General Lisa O. Monaco, “Corporate Crime Advisory Group and Initial Revisions to Corporate Criminal Enforcement Policies,” (Oct. 28, 2021), available at

  14. Text of Policy at 5.

  15. Id.; see Monaco Memo.

  16. Text of Policy at 5; see, e.g., “U.S. Department of Justice Criminal Division Evaluation of Corporate Compliance Programs,” (updated March 2023), available at

  17. Text of Policy at 4.

  18. Id.

  19. Id.

  20. Note, “In cases where the company is being jointly prosecuted by a USAO and another [DOJ] office or component, or where the misconduct reported by the company falls within the scope of conduct covered by VSD policies administered by other [DOJ] offices or components, the USAO will coordinate with, or, if necessary, obtain approval from, the [DOJ] component responsible for the VSD policy specific to the reported misconduct when considering a potential resolution and before finalizing any resolution. Consistent with relevant provisions of the Justice Manual and as allowable under alternate VSD policies, the USAO may choose to apply any provision of an alternate VSD policy in addition to, or in place of, any provision of this policy.” Text of Policy at 2 (citations omitted).

  21. Text of Policy at 5.

  22. Press Release and Text of Policy; Monaco Memo at 7.

  23. Press Release.

  24. Text of Policy at 5.

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