DOJ Continues to Incentivize Self-Disclosing Misconduct, But When and Where May Be Complicated: Takeaways From the SDNY’s Corporate Enforcement and Voluntary Self-Disclosure Program

On February 24, 2026, the U.S. Attorney’s Office for the Southern District of New York (SDNY) announced a Corporate Enforcement and Voluntary Self-Disclosure (VSD) Program “for illegal activity involving fraud and financial misconduct affecting market integrity,” aimed at incentivizing companies to quickly report to the SDNY potential wrongdoing and cooperate with law enforcement’s investigation of the conduct.... By: Goodwin