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"Liberty Mutual and BofA Securities: Two Declinations, Many Lessons"

Two DOJ Declinations, One Clear Message: Why Self-Disclosure, Cooperation, and Remediation Matter More Than Ever

In 2025, the DOJ declined prosecution in two high-profile cases—Liberty Mutual (FCPA violations) and Bank of America Securities (market manipulation)—despite evidence of misconduct. Issued under the DOJ’s revised Corporate Enforcement and Voluntary Self-Disclosure Policy, these resolutions highlight what it now takes for companies to secure a declination. This article reviews each case and distills the core lessons for corporate counsel and compliance teams, including the importance of timely self-disclosure, proactive cooperation, effective remediation, and meaningful compliance program enhancements. Together, the declinations offer a clear, practical blueprint for companies seeking to reduce enforcement risk in today’s regulatory environment.

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