It is well and good that DOJ is providing updates to their corporate enforcement policies. It is always best to know the ground rules before providing advice about interacting with the government. However, without some more detailed examples on just how these new policies play out, self disclosure still carries a great risk. It also makes it harder to meet expectations, for both the client and the government. That's why it becomes even more important to engage outside counsel like those of us in Jones Walker's corporate compliance and white collar defense team before you make a decision to self disclose.

But in providing transparency to the potential incentives, we are underscoring that a corporation that falls short of our expectations does so at its own risk. Make no mistake - failing to self-report, failing to fully cooperate, failing to remediate, can lead to dire consequences.

www.justice.gov/...