Peter Skinner spoke to the Anti-Corruption Report about the United States Attorneys’ Offices Voluntary Self-Disclosure Policy (VSD), a new Department of Justice (DOJ) guidance for U.S. Attorneys’ Offices addressing voluntary self-disclosures.
According to Peter, this new policy is “largely the same” as the DOJ’s Revised Corporate Enforcement Policy (CEP), which also provides incentives for corporations to disclose misconduct. However, he added that “the CEP is arguably more favorable to companies because it provides a presumption of declination for full compliance, while the VSD policy only provides a presumption of no guilty plea.”
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