Robins Kaplan – The DOJ’s 2025-2026 policy reset makes declinations more predictable, narrows the use of monitors, and sharpens enforcement around individual accountability, cartel and TCO exposure, government-program fraud, and national-security harms. For companies confronting potential criminal misconduct, the question is no longer just whether the DOJ will investigate. The more important question is how prosecutors will decide whether to charge the corporation itself, offer a negotiated resolution, or decline the case altogether.

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