New SDNY Self-Reporting Adds Complexity to Corporate Self-Reporting Decisions

On February 24, 2026, the United States Attorney’s Office for the Southern District of New York (the “Office”) revised and expanded its “Corporate Enforcement and Voluntary Self-Disclosure Program for Financial Crimes” (the “Program”) to incentivize companies to self-report potential criminal conduct and standardize the way in which the Office issues declinations. The changes are part of a broader U.S. Department of Justice (“DOJ”) effort to promote early disclosure, cooperation, and... By: Morrison & Foerster LLP