Overview
- In March 2026, the Justice Department introduced a single Corporate Enforcement and Voluntary Self‑Disclosure Policy for corporate crimes to standardize incentives for self‑reporting.
- New DOJ guidance confirms the National Security Division is the right place to send voluntary disclosures tied to export controls, sanctions, or other national‑security laws.
- Reports filed only with civil regulators such as OFAC, BIS, or DDTC generally do not earn credit under the DOJ policy, though a good‑faith disclosure to one DOJ unit will carry over if another takes the case.
- The guidance signals a shift toward declinations for companies that promptly disclose, fully cooperate, and fix problems, moving away from treating export‑control and sanctions cases as automatically aggravating.
- DOJ’s first declination under the policy involved Balt SAS, which self‑reported an FCPA scheme, disgorged about $1.2 million, and saw two related individuals indicted, offering a roadmap that stresses early reporting, concrete remediation, and ongoing cooperation.