Policy · March 20, 2026 · 7 min

DOJ’s Corporate Enforcement Pathway: A Reader’s Guide

The Department of Justice’s updated corporate enforcement memorandum revises self-disclosure timing, cooperation credit, and monitor-imposition standards.

The Department of Justice has released an updated corporate-enforcement memorandum that materially revises the standards governing self-disclosure, cooperation credit, and the imposition of compliance monitors. Companies and counsel should familiarise themselves with the new framework, particularly the presumption-of-declination provisions, the recalibrated mitigation framework, and the new criteria for monitor selection and duration.