To Disclose Misconduct—or Not? What the SDNY’s New Program Means for Companies

The U.S. Attorney’s Office for the Southern District of New York (the SDNY) recently announced a novel voluntary self-disclosure program (the Program) for companies to report misconduct involving financial crimes. The Program enhances the incentives for a company to report misconduct to the SDNY by promptly promising the company that the SDNY will provisionally decline prosecution.... By: Ballard Spahr LLP