In September 2025, the U.S. Attorneys’ Office for the Eastern District of Pennsylvania (EDPA) announced that it would be implementing a White-Collar Justice Program to strengthen its white- collar enforcement framework. Among other things, the program will “empower Assistant United States Attorneys to aggressively pursue complex investigations and significant new matters on their own initiative.”
This announcement demonstrates another step in federal districts ramping up their white-collar enforcement efforts while encouraging robust procedures for compliance and self-disclosure. This is a trend several years in the making: in September 2022, then-Deputy Attorney General Lisa Monaco directed U.S. attorneys and others within the DOJ to review their policies on corporate voluntary self-disclosure, and to draft and share a formal written policy to incentivize such self-disclosure, if one was lacking.
Since October 2021, the Department of Justice (DOJ) has been implementing a variety of changes to its corporate criminal enforcement policies. These efforts all reflect DOJ’s focus on individual accountability, punishing recidivist misconduct, prioritizing compliance and responsible corporate citizenship, promoting corporate self-disclosure, and incentivizing whistleblowers to come forward. The latest development in these efforts is the Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals that DOJ released on April 15, 2024.
Six months from the date of closing. That’s how long acquiring companies have under the newly announced Department of Justice (DOJ) Mergers and Acquisitions (M&A) Safe Harbor Policy to disclose misconduct discovered in the context of a merger or acquisition – whether discovered pre or post-acquisition. And the acquiring company has one year from the date of closing to remediate, as well as provide restitution to any victims and disgorge any profits.
Over the last two years, the DOJ has made clear its priority to encourage companies to self-disclose misconduct aiming to ...
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Recent Updates
- Service and Justice: Veterans in Law – Speaking of Litigation Video Podcast
- Sixth Circuit Says It Again: Outside Counsel’s Internal Investigations Are Privileged and Protected from Disclosure
- Eleventh Circuit Allows Qui Tam Relators to Avoid Complaint Dismissal by Using Information Obtained in Discovery
- EDPA Strengthens Its Approach to White-Collar Enforcement
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