Ronald Reagan once said “The nine most terrifying words in the English language are: I’m from the Government, and I’m here to help.”
I was reminded of this quote upon reading Assistant Attorney General Kenneth Polite’s recent speech announcing the “first significant changes to the Criminal Division’s CEP [Corporate Enforcement Policy] since 2017.” (See here for a prior post analyzing the 2017 CEP).
Per Polite’s language, I guess that means that the revisions to the CEP released in early 2019 (see here) as well as late 2019 (see here) were not “significant.”
Even though the DOJ has been actively encouraging voluntary disclosure for approximately 15-20 years, Polite stated: