To Disclose or Not to Disclose? SDNY Provides Increased Incentives Under Revised Corporate Enforcement and Voluntary Self-Disclosure Program

On February 24, 2026, the U.S. Attorney for the Southern District of New York (SDNY), Jay Clayton, announced a revised Corporate Enforcement and Voluntary Self-Disclosure Program for Financial Crimes (the “Program”) for the SDNY U.S. Attorney’s Office (the “Office”). The revised Program is largely consistent with the Department of Justice’s (DOJ) Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) and provides that a company will receive a declination if the company voluntarily... By: Cadwalader, Wickersham & Taft LLP