On March 10, 2026, the US Department of Justice (DOJ) released what it described as its first-ever Department-wide corporate enforcement policy for criminal matters. While the new policy appears to be substantively identical to the Criminal Division’s May 2025 Corporate Enforcement and Voluntary Self-Disclosure Policy which we wrote about last year, the impact of the announcement lies in the final sentence of DOJ’s press release. According to the press release, Deputy Attorney General Todd Blanche declares that the policy “supersed[es] all” individual corporate enforcement policies issued by DOJ components and US Attorney’s Offices, even though the new policy does not expressly say so on its face.
The policy continues to incentivize companies to timely self-report misconduct and does not appear to change DOJ’s core policies regarding corporate enforcement. However, the broad framing directly calls into question the continued validity of district-specific corporate enforcement policies, such as those issued by the US Attorney’s Office for the Northern District of California (NDCA) and the Southern District of New York (SDNY). Indeed, the new SDNY policy was announced only two weeks ago (which we commented on in a recent post) and notably opened the door to corporate declinations in instances where potential aggravating factors noted in the department-wide policy are present.
We will continue to track and report on developments in the manner on which DOJ and its components implement this new framework and how it may alter expectations for corporate voluntary self-reporting of criminal conduct.
