National Law Review
6/24/2026
![Speaking of Litigation – Episode 24: DOJ’s New Self-Disclosure Rules: Decide Fast or Lose the Credit [Podcast]](https://natlawreview.com/sites/default/files/styles/article_image/public/2026-06/dept%20of%20justice%20DOJ%20website%20health%20care%20fraud%20federal%20criminal%20law.jpg.webp?itok=pkTO6FsB)
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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