DOJ Declination Highlights Importance of Early Disclosures, Law Firm Says

DOJ’s recent decision not to prosecute a biochemical company that was part of an illegal export scheme involving China (see 2406040069 and 2405220037) underscores the importance of companies being “particularly aggressive” about deciding whether to submit an early voluntary disclosure to the U.S. government, McGuire Woods said in a client alert. The firm noted that DOJ decided not to prosecute the company, MilliporeSigma, “because of its prompt disclosure soon after it detected suspicious activity” -- the company disclosed the issue one week after hiring an outside lawyer. “Companies that wait too long to disclose or affirmatively choose not to file voluntary self-disclosures are at greater risk of being prosecuted or forfeiting valuable cooperation credit,” the firm said.