Law360, Expert analysis: On 10 March 2026, the US Department of Justice (DOJ) released its first-ever departmentwide Corporate Enforcement and Voluntary Self-Disclosure Policy, establishing a uniform framework for how the DOJ approaches and resolves corporate criminal cases. According to the analysis, with input from Sean Tonolli, Partner at Cahill Gordon & Reindel LLP and Sarah Ruckriegle, Associate at Cahill Gordon, the policy extends the Criminal Division’s existing approach across the DOJ, emphasising voluntary self-disclosure, co-operation and remediation. It introduces greater consistency and predictability in outcomes, while also tightening certain requirements and limiting discretion in key areas. The policy marks a shift toward standardised corporate enforcement, though it creates tensions with more lenient, recently introduced programmes such as the Southern District of New York’s (SDNY) financial crimes initiative.