Your company uncovers a massive criminal scheme.

Are you gonna go down with the ship or are you gonna grab onto the lifeboat that the Justice Department has sent your way?

The era of big corporate fines is over, and you have to make sure that you get your company through this without a big fine.

What do you do?

The Justice Department’s corporate enforcement policy has been revised, and it makes it very clear you have to:

1. Voluntarily disclose your criminal activity
2. Cooperate with the Justice Department’s investigation
3. You have to remediate your corporate compliance program to make sure it doesn’t happen again.

All of those things add up to a declination, meaning nothing happens to the company, and you have to only disgorge your ill-gotten gains.

But all of this is contingent on one issue, which we’re gonna talk about in the next episode.

The Ethics and Compliance Q and A show is produced by One Stone Creative.