Sargeant, Harris and Stanley Examine DOJ Corporate Enforcement Policy in Corporate Compliance Insights

05.13.2026

Stinson LLP Partners Bernadette Sargeant and Reginald Harris and attorney Alexandra Stanley authored an article for Corporate Compliance Insights examining the U.S. Department of Justice's new corporate enforcement and voluntary self-disclosure policy (CEP) and its implications for companies that uncover potential misconduct.

In the article, "Navigating Self-Reporting Under the DOJ's New Corporate Enforcement Policy," the authors explain how the CEP replaces prior agency-specific frameworks with a standardized DOJ-wide approach to evaluating self-disclosure, cooperation and remediation. They highlight the policy's three-tier structure, which offers potential declinations, nonprosecution agreements or reduced penalties depending on the timing and quality of a company's disclosure and cooperation. The authors also point to the recent Balt SAS resolution as an early example of the policy in action, underscoring the DOJ's emphasis on timely self-reporting and full cooperation.

The article further discusses how the CEP is reshaping corporate compliance strategy, particularly in light of the DOJ's whistleblower program and its 120-day window for companies to self-report after an internal disclosure. The authors emphasize that companies seeking to benefit from the policy must have investigation protocols, escalation procedures and remediation frameworks in place before issues arise, enabling faster decision-making when potential misconduct is identified.

Sargeant is an experienced investigator and litigator, guiding clients through sensitive internal investigations and complex litigation. She handles workplace and government investigations and helps clients navigate regulatory compliance and ethics requirements.

Harris provides strategic counsel and representation in internal investigations, corporate compliance matters, white collar criminal defense and civil trial litigation. He has extensive experience investigating allegations of workplace safety violations, employment discrimination, financial misconduct and regulatory noncompliance.

Stanley's practice focuses on federal and state government enforcement actions and investigations. She has experience in representing clients before the U.S. Department of Justice, the Securities and Exchange Commission, and a variety of other agencies.

Visit Corporate Compliance Insights to read the full article.