Nicole Sprinzen, vice chair of the White Collar Defense & Investigations group, spoke with Law360 about the changes in white collar enforcement that have taken place over the past six months. Among them is the Justice Department’s revised corporate enforcement policy, rolled out in May, that offers companies a path for avoiding criminal resolutions if they voluntarily disclose misconduct.  

"To a company, a presumption of a declination is not a guarantee, and so [previously] there was a lot of uncertainty," Nicole said. "With the guidance now, it's more than a presumption that there will be a declination, absent significant aggravating circumstances. That brings more confidence to a potential outcome."

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