U.S. DOJ Implements Uniform Corporate Enforcement and Voluntary Self-Disclosure Framework Across All Components Except Antitrust
On March 10, 2026, the U.S. Department of Justice (DOJ or the Department) announced a new Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP). For the first time, the policy establishes a uniform framework governing corporate enforcement decisions across all DOJ components, including U.S. Attorneys’ Offices nationwide, with the exception of the Antitrust Division, which will maintain its separate and longstanding leniency policy. DOJ’s stated goal for the CEP is to promote greater consistency, predictability, transparency, and fairness in DOJ’s prosecutions of corporate criminal matters.
Sidley Secures Early Termination of Corporate Probation in Clean Air Act Matter for Leading Aftermarket Automotive Company
Sidley obtained the early termination of corporate probation, along with relief from all remaining unpaid criminal fines, for a leading aftermarket automotive company in United States v. Rudy’s Performance Parts, Inc., Case No. 24-cr-00336 (D.D.C. Mar. 12, 2026).
Antitrust Crime Enforcement May Escalate Under New Chief
A recent speech by Acting Deputy Assistant Attorney General Daniel Glad signals that the U.S. Department of Justice (DOJ) Antitrust Division will continue actively pursuing criminal antitrust violations, with a focus on individual accountability and significant prison sentences as a deterrent. Glad also highlighted increased enforcement activity, the expanding role of the Procurement Collusion Strike Force, and the impact of the new antitrust whistleblower rewards program. Read the full article to learn more about what these developments could mean for companies and their compliance programs.
New U.S. DOJ Antitrust Leadership Signals More Criminal Prosecutions and Longer Prison Sentences
Two weeks after a leadership shakeup in the U.S. Department of Justice (DOJ) Antitrust Division, Acting Deputy Assistant Attorney General for Criminal Enforcement Daniel W. Glad stressed in his first public remarks that the Division’s criminal enforcement program will remain highly active and that individuals involved in criminal antitrust offenses should continue to expect lengthy prison sentences. To drive home this message, Glad highlighted the fact that the Antitrust Division opened nearly 100 criminal investigations in FY 2025 and secured prison sentences that reflected more than a 1,200% increase in prison days imposed year-over-year. He cautioned that individuals who commit criminal antitrust offenses should “be aware that what’s on the line isn’t just a fine — it’s their … liberty.”
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Matthew Podolsky Joins as Partner in Sidley’s White Collar Defense and Investigations and Commercial Litigation and Disputes Practices in New York
Sidley is pleased to announce that Matthew Podolsky has joined the firm as a partner in its White Collar Defense and Investigations practice and its Commercial Litigation and Disputes practice in New York. He joins Sidley after a distinguished career as a federal prosecutor, most recently serving as the Acting U.S. Attorney for the Southern District of New York (SDNY).
Call of Duties: New U.S. Trade Fraud Task Force Signals Increased Tariff Enforcement is Coming
On August 29, 2025, the U.S. Department of Justice (DOJ) and Department of Homeland Security (DHS) announced their partnership on the cross-agency Trade Fraud Task Force. Per DOJ’s press release, the Task Force will bring robust enforcement against importers and other parties that seek to defraud the United States.
President Trump Signs “Fair Banking” Executive Order Directing Financial Regulators to Remedy Past and Present Debanking Practices
On August 7, 2025, President Donald Trump signed an executive order titled “Guaranteeing Fair Banking for All Americans,” directing federal agencies to combat “debanking” — the denial or termination of financial services based on political views, religious beliefs, or industry affiliation. The executive order expands on numerous recent federal and state initiatives targeting debanking — including the joint U.S. Department of Justice (DOJ)/Commonwealth of Virginia Equal Access to Banking Task Force, two recent bills introduced in the U.S. Senate, and actions by the federal financial regulators to remove “reputation risk” as a supervisory consideration.
Tariff Evasion Is Within DOJ’s Crosshairs: Potential Criminal and Civil Consequences for Noncompliance With Increased U.S. Tariffs
The first six months of the current Trump administration have made it clear that tariffs are here to stay and that noncompliance — intentional or otherwise — will be subject to potentially significant criminal and civil liability. Indeed, the administration has committed to an August 1, 2025, deadline for new country-specific tariffs to begin. The scale, speed, and complexity of the changes in the U.S. tariff landscape over the previous six months (which will likely continue) has created an environment ripe for noncompliance. (more…)