DOJ’s New Corporate Enforcement & Voluntary Self-Disclosure Policy: Implications for Government Contractors

On March 10, 2026, DOJ issued its first-ever department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), replacing the prior patchwork of component-specific frameworks with a single uniform standard for all non-antitrust corporate criminal matters. For government contractors, this brings conduct like procurement and government program fraud under a published framework with defined declination criteria and graduated penalty reductions. This session examines how the CEP reshapes the self-disclosure calculus for contractors, including its interaction with FAR mandatory disclosure obligations.