Shifts at DOJ alter corporate self-disclosure calculus

“Commentary has focused on these incentives as if they are self-executing. But they are not. They depend on a critical predicate: that companies face a meaningful risk of detection and prosecution absent self-disclosure.”

- Hui Chen in Law360

When the DOJ released its “new” Corporate Enforcement Policy, much of the compliance community rushed to treat it as a game‑changer. In this Law360 article (also here), our co-founder, Hui Chen, takes a step back, unpacking why the promised certainty may be more illusion than reality—and why context and critical thinking matters more than ever.

Along the way, she reframes the compliance program not as a shield against prosecution, but as a tool for detecting signals and enabling better decisions. The takeaway: slow down, look past the hype and headlines, and ground compliance decisions in context, evidence, and thoughtful analysis—not fear.

Also, be sure to check out our complementary podcast episode on this topic here.