DOJ’s Revised CEP May Help Consistency in Outcomes for Self-Disclosure

Report on Medicare Compliance quoted Covington white collar lawyer Dan Suleiman in an article examining DOJ’s updated corporate enforcement and voluntary self-disclosure policy (CEP), which was rolled out on March 10 and extended the policy’s application from the Criminal Division to the entire department and its 93 U.S. attorneys’ offices.

Dan, a former counselor to the Assistant Attorney General for the DOJ’s Criminal Division from 2012-2013, said the update was not a “sea change” from the May 2025 version but noted that “they’re trying to achieve some consistency” in the outcome of self-disclosures in criminal matters. He explained that a company that may not have gained traction with a U.S. attorney’s office under the prior CEP now has stronger footing: “you can invoke this policy with a U.S. attorney and it should apply.”

Dan also pointed to a notable clarification in the new version, observing that DOJ “tries to flesh out the definition of making a disclosure to the appropriate component,” including new language addressing how good-faith disclosures to regulatory agencies or other government entities may qualify under certain circumstances.