The path for any company seeking to earn cooperation credit from the Department of Justice (DOJ) starts at zero. Officials at the agency have been diligent in noting this while promoting the new methods available for businesses to earn steeper penalty discounts than ever before.
Getting to that point, though, takes work, and companies might not understand what terms like “timely,” “reasonably,” and “appropriate” mean to the DOJ in certain circumstances. Unfortunately, those determinations are case by case. But there is still much to be learned from recent enforcement examples.
