Federal Policy
DOJ Implements Corporate Enforcement Policy
March 19, 2026
The U.S. Department of Justice (DOJ) has introduced a new Corporate Enforcement and Voluntary Self-Disclosure Policy designed to create a consistent framework for handling corporate misconduct. Under this policy, companies that voluntarily disclose wrongdoing, fully cooperate with investigations, and promptly remediate issues may avoid prosecution, provided there are no aggravating factors. This policy aims to enhance predictability and fairness in white-collar criminal enforcement, impacting how government contractors and vendors manage compliance risks and legal exposure.
- Why this matters: Procurement professionals should recognize that contractors with robust compliance and self-disclosure programs may benefit from reduced enforcement risks under DOJ policies.
- Organizations engaged in government contracts should evaluate and potentially strengthen internal controls and reporting mechanisms to align with DOJ expectations.
- Legal and compliance teams supporting contractors must understand the policy's criteria to advise on risk mitigation and voluntary disclosure strategies.
- This policy signals DOJ's emphasis on cooperation and remediation, which could influence contract eligibility and reputational considerations in federal procurement.
The Government has offered no evidence whatsoever that Powell committed any crime other than displeasing the President.
— Federal Judge
The DOJ will not prosecute a company that voluntarily self-discloses misconduct, fully cooperates, timely remediates, and has no aggravating circumstances.
— DOJ Policy
Agencies
U.S. Department of Justice