DOJ Pilot Program Changes Calculus on Corporate Self-Disclosure

Here's the intro from this Client Update: "The Criminal Division of the U.S. Department of Justice (DOJ) announced a Pilot Program on Voluntary Self-Disclosures for Individuals (Pilot Program) on April 15th. Under the new policy, individuals who were involved in certain types of corporate criminal misconduct, who voluntarily disclose that conduct to the Criminal Division, and who meet certain other criteria will be eligible to receive a non-prosecution agreement (NPA). This pilot program has the potential to change in-house counsel's decision-making on whether and when to voluntarily disclose corporate misconduct by incentivizing employees who participated in the misconduct to be first in the door at DOJ."