Corporate Self-Reporting and Cooperation Program

In February 2026, the Office adopted the SDNY Corporate Enforcement and Voluntary Self-Disclosure Program for Financial Crimes. Consistent with the Department of Justice’s March 10, 2026 Corporate Enforcement and Voluntary Self-Disclosure Policy, SDNY’s program aligns public, company, and victims’ interests to promote effective and effective prosecution of financial crime. 

Under this program, companies that self-report qualifying illegal activity, cooperate fully, and remediate harm caused by misconduct will have a clear and predicable path to a declination. Once a company makes a qualifying self-report, the Office will issue a conditional declination letter stating its intent to decline prosecution if the company cooperates with the Office’s investigation and satisfies all eligibility requirements, including full restitution of victim losses. Once a company fulfills its cooperation, remediation, and restitution obligations, the Office will issue a final declination notice, concluding the matter without criminal charges.

The Office’s program bolsters law enforcement’s ability to detect, prosecute, and remediate financial crimes. By establishing a transparent framework that rewards voluntary disclosure, it encourages responsible businesses to surface criminal conduct that might otherwise go undetected. By requiring genuine cooperation, including against senior corporate executives, it converts self-reporting companies into partners in the prosecution of wrongdoers. And by making restitution and remediation upfront commitments rather than contingencies of resolutions reached years later, it enables the Office to promptly aid victims of financial misconduct.

The program has begun to produce results. Since the Office announced the program, there has been a substantial increase in corporations reporting misconduct compared to prior years. In most cases, the Office has issued a conditional declination letter within two to three weeks of receiving a self-report. Information disclosed through those self-reports has alerted the government to previously unknown illegal activity, and corporate cooperation has significantly accelerated the Office’s ability to bring criminal charges against culpable individuals. As the Office announced previously, information and cooperation provided under the program enabled the Office to bring charges against culpable individuals within approximately six weeks of a self-report.

Companies considering a disclosure under the program should review the materials linked below. The Office will also consult with companies on a no-name basis regarding their eligibility or the program’s features.

SDNY’s Corporate Enforcement and Voluntary Self-Disclosure Program for Financial Crimes is one of many Office initiatives designed to detect, deter, and punish sophisticated financial crimes. SDNY and its law enforcement partners continue to investigate and prosecute corporate leaders and corporations, and in the last twelve months the Office has devoted additional personnel and resources to protecting American investors and markets. Companies that knowingly decline to report criminal misconduct by their management should expect to be prosecuted.

SDNY Corporate Enforcement and Voluntary Self-Disclosure Program for Financial Crimes

Model Conditional Declination Letter