Criminal Division Corporate Enforcement
The Criminal Division is a leader in the Department’s corporate enforcement efforts, having pioneered a corporate enforcement and voluntary self-disclosure policy in the Fraud Section’s Foreign Corrupt Practices Act Unit that was expanded to the Criminal Division in 2018. The Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) served as a model for voluntary self-disclosure programs adopted across the Department. Today, the Criminal Division, led by the Fraud Section in coordination with the Money Laundering and Asset Recovery Section, is a center of innovation in corporate prosecutions and enforcement policy.
In August 2024, the Department announced a new tool to identify corporate misconduct and hold wrongdoers accountable: the Corporate Whistleblower Awards Pilot Program (Pilot Program). Led by the Criminal Division, this Pilot Program is designed to incentivize individuals with information about corporate misconduct in certain areas to come forward and report to the Department. The Pilot Program is also designed to incentivize companies to disclose misconduct when they learn about it. To that end, the Criminal Division has issued a temporary amendment to the CEP that allows companies who receive a whistleblower’s report internally to qualify for the presumption of a declination when the company: (1) self-reports the conduct to the Department within 120 days of receiving the whistleblower’s submission, even if the whistleblower reports to the Department before the company does, and (2) meets the other requirements for voluntary self-disclosure and presumption of a declination under the policy.
Companies that wish to voluntarily self-report misconduct can do so here: Fraud Section; MLARS
Additional information on our corporate enforcement policies and prosecutions can be found below.
- Assistant Attorney General Polite January 17, 2023 Speech
- Criminal Division’s Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP)
- Criminal Division’s Temporary Amendment to the CEP
- Criminal Division’s Corporate Whistleblower Awards Pilot Program
- Corporate Crime Database
- Criminal Division Resolutions:
- Declinations
- Criminal Division’s Pilot Program Regarding Compensation Incentives and Clawbacks