Rare Declinations by DOJ’s National Security Division Demonstrate Potential Benefits of Voluntary Disclosure — but Could Obscure the Risks
In a recent speech, Matthew R. Galeotti, the head of the DOJ’s Criminal Division, discussed changes in how the DOJ intends to conduct corporate enforcement. The speech, which followed the recent announcements of declinations by the National Security Division, provides insight into how the DOJ is likely to conduct its investigations and make charging determinations as well as guidance to companies on how to navigate a DOJ with changing enforcement priorities. Morgan Lewis partners Justin Weitz, Loyaan Egal and Katelyn Hilferty and associate Moshe Klein encourage companies to remember that self-disclosure has downsides, too.
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