Last week, the Department of Justice (DOJ) announced the Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the Program). Pursuant to the Program, “an individual who voluntarily self-discloses original information about criminal misconduct, including the complete extent of their own role in the misconduct, fully cooperates, and satisfies the other conditions [in the Program], the reporting individual will receive” a nonprosecution agreement (NPA) as resolution of their criminal exposure. Individuals who fall short of the full criteria for an NPA may still receive that outcome where the Criminal Division exercises its discretion.
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