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Corporate Enforcement

The Criminal Division is a leader in the Department’s white-collar and corporate enforcement efforts. White-collar crime poses a significant threat to U.S. interests. Unchecked fraud in U.S. markets and government programs robs hardworking Americans and harms the public fisc.  The deadly activities of Cartels and TCOs are enabled by international money laundering organizations and other financial facilitators.  Illicit financial and logistical networks undermine our national security by enabling shadow-banking for and sanctions evasion by hostile nation-states and terror regimes.  The Criminal Division is committed to rooting out such insidious conduct in corporate and white-collar investigations guided by three core tenets: (1) focus; (2) fairness; and (3) efficiency.  The Criminal Division’s White-Collar Enforcement Plan can be found here.

Within the Criminal Division, the Fraud Section pioneered a corporate enforcement and voluntary self-disclosure policy in the Foreign Corrupt Practices Act Unit in 2016.  In 2018, that policy, the Criminal Division’s Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) was extended to the entire Criminal Division.  The Criminal Division’s 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 (MLARS), is a center of innovation in corporate prosecutions and enforcement policy.

The Criminal Division’s CEP can be found here.

The Criminal Division’s Crediting Policy can be found here.

Companies that wish to voluntarily self-report misconduct can do so here.

Individuals that wish to voluntarily self-report misconduct can do so here.

Individuals that wish to blow the whistle can do so here.

Criminal Division Corporate Enforcement Pilot Programs

In May 2025, the Criminal Division updated the Corporate Whistleblower Awards Pilot Program (Whistleblower Pilot Program), a tool to identify corporate misconduct and hold wrongdoers accountable, to align with the Department’s highest priorities. Led by the Criminal Division, this Whistleblower Pilot Program is designed to incentivize individuals with information about corporate misconduct in certain areas to come forward and report to the Department.  The Whistleblower 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.

In April 2024, the Criminal Division announced a Pilot Program on Voluntary Self-Disclosures For Individuals designed to encourage voluntary self-disclosures by participants in certain types of criminal conduct involving corporations. Those who participate in the pilot program and self-disclose, fully cooperate, pay applicable victim compensation, and return ill-gotten gains will receive a non-prosecution agreement.

In March 2023, the Criminal Division announced the Criminal Division's Pilot Program Regarding Incentives and Clawbacks. This two-part pilot program is a three-year initiative that requires every company resolving with the Criminal Division to implement criteria related to its compliance in its compensation and bonus system and provides for a fine reduction for companies that clawback or withhold compensation.  The Criminal Division published a corporate enforcement note on the pilot program in November 2024.

Corporate Enforcement Matters