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Key Takeaways

  • A unified enforcement policy is now in effect. The DOJ released its first-ever department-wide Corporate Enforcement Policy (CEP), replacing a patchwork of office-specific policies and creating one consistent framework for how the DOJ handles corporate misconduct cases.
  • Companies that come forward can avoid prosecution. If a company voluntarily discloses wrongdoing, fully cooperates, remedies the harm, and has no aggravating circumstances, the DOJ will decline to prosecute — though the company must still pay back any ill-gotten gains.
  • There’s a “Near Miss” path for companies that fall short. Companies that don’t qualify for a full declination — due to aggravating factors or incomplete self-disclosure — can still receive favorable treatment, including a shorter agreement, no compliance monitor, and at least a 50% reduction in fines.
  • Antitrust cases play by different rules. The CEP carves out antitrust violations entirely; those cases continue to follow the Antitrust Division’s separate Leniency Policy, which has its own tiered structure for companies seeking protection.
  • The bottom line for companies: invest in compliance and act fast. The CEP rewards companies that catch and report problems early. Having a strong internal compliance program isn’t just good governance — it’s now the clearest path to avoiding criminal liability if something goes wrong.

Vedder Price Partner Biggin is set to speak at the Future Global Leaders Academy on January 28, as part of Airline Economics’ Growth Frontiers Global – Dublin. During her session, Helen will discuss default remedies available under the Cape Town Convention and cases where those remedies have been utilized.

AB 288: California Attempts to Step In as Federal Labor Enforcement Stalls
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Vedder Price is also a proud sponsor of the event. For further information and to register, click here.

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