what the ultimate outcome is from DOJ's perspective.

So the voluntary self-disclosure in the CEP policy is built around three escalating tiers of outcome.

Full declination, what they call the near-miss path, and what doesn't fall into these categories.

Full declination is the most desired and the most difficult to obtain outcome.

If a company is self-disclosing, it requires that four conditions be met.

First, that the company voluntarily self-disclose to an appropriate criminal component.

This implies that the voluntary self-disclosure must be made early, often before all the facts regarding the misconduct are fully known, or before the company has completed its full internal investigation, or sometimes even without any internal investigation whatsoever.

And if we don't get out there in front of this, it's going to be a bigger problem.