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 May 19, 2025, the Department of Justice (“DOJ”) announced its plan to use the False Claims Act to investigate and pursue claims of civil rights violations against federal fund recipients.  The plan, entitled the Civil Rights Fraud Initiative (the “Initiative”), seeks to target universities’ and government contractors’ use of diversity, equity, and inclusion (“DEI”) programs.

On February 22, 2023, the United States Department of Justice issued the United States Attorney’s Offices’ Voluntary Self-Disclosure Policy for corporate criminal enforcement, which sets forth the criteria the 94 United States Attorney’s Offices will use to determine the appropriate resolution for a corporate entity that voluntarily self-discloses misconduct to a USAO. The VSD Policy is intended to provide incentives, including declinations or reduced fines, to corporations that timely disclose misconduct, cooperate with the DOJ’s investigation, and remediate misconduct. It applies to all USAOs and is effective immediately.