Self‑Report or Not? SDNY’s New Corporate Self-Disclosure Program Intensifies the Early Decision

Last week, the U.S. Attorney’s Office for the Southern District of New York unveiled a new Corporate Enforcement and Voluntary Self‑Disclosure Program for Financial Crimes. SDNY’s Program offers declination to companies that promptly self‑report financial‑related offenses. The new policy also provides other guarantees: it removes subjective disqualifiers (such as offense seriousness or pervasiveness), limits financial consequences to full restitution, and provides conditional declination letters... By: Cozen O'Connor