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National Law Review
National Law Review
6/24/2026
Speaking of Litigation – Episode 24: DOJ’s New Self-Disclosure Rules: Decide Fast or Lose the Credit [Podcast]

Speaking of Litigation – Episode 24: DOJ’s New Self-Disclosure Rules: Decide Fast or Lose the Credit [Podcast]

Short summary

The DOJ's new Corporate Enforcement Policy sets a 120-day deadline for companies to self-disclose misconduct or lose cooperation credit. This transforms compliance from a legal issue into a business-critical risk decision requiring fast internal investigation and escalation. General counsels and C-suite leaders must now move significantly faster on corporate misconduct cases.

  • 120-day deadline to self-disclose after whistleblower complaint or lose DOJ cooperation credit
  • Shifts decision-making from legal judgment to business-critical financial and reputational risk
  • Requires accelerated internal investigation and escalation timelines

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