On February 24, 2026, the U.S. Attorney’s Office for the Southern District of New York (“Office”) announced a new Corporate Enforcement and Voluntary Self-Disclosure Program for illegal activity involving fraud and financial misconduct (“Program”).  While the Office already maintains a voluntary corporate self-disclosure program, the new Program’s stated purpose is to improve corporate self-reporting to “root out wrongdoing more quickly” and “strengthen the integrity of the financial markets” while simultaneously establishing “clear guidelines and predictable treatment for companies” that promptly disclose criminal activity and fully cooperate with law enforcement.   

On December 14, a multinational telecommunications company headquartered in Stockholm, Sweden (the “Company”), announced it had reached agreement with the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) to extend the Company’s independent compliance monitorship by one year, to June 2024.  The agreement to extend the monitor, which had been required under a 2019 resolution with the DOJ, was the result of the DOJ determining that the Company had failed to adequately disclose compliance matters that it had investigated in Iraq.