Other Federal Agency Updates
Discussion
DOJ Releases Agency-Wide Corporate Self-Disclosure Policy
On March 10, 2026, the Department of Justice (DOJ) released its first agency-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), creating a uniform, predictable framework under which employers that discover potential criminal misconduct may reduce or avoid criminal prosecution by self-disclosing and cooperating with investigations. The CEP is applicable to potential criminal penalties for violations of laws such as safety and health regulations, environmental compliance, immigration, and anti-bribery provisions. Antitrust matters are specifically excepted from the policy. The CEP offers three paths depending on the circumstances: (1) a full declination of prosecution for companies that voluntarily self-disclose, fully cooperate, and timely remediate with no aggravating factors; (2) a “near miss” path offering a non-prosecution agreement and a 50–75% fine reduction for companies that self-reported in good faith but fall short of full declination; and (3) a discretionary resolution path for all other cases, capping fine reductions at 50%. Importantly, self-disclosure must occur as soon as reasonably practicable, and not later than 120 days after receiving an internal whistleblower report. Employers should treat this as an opportunity to review and strengthen internal compliance programs and reporting systems, train managers and supervisors on how to handle internal complaints, and ensure investigation procedures are structured to enable timely, well-documented decision-making, should self-disclosure become necessary.
Trump Administration Proposes National Framework for AI
On March 20, 2026, the Trump administration released “A National Policy Framework for Artificial Intelligence,” providing a non-binding set of legislative recommendations urging Congress to adopt a federal approach to AI regulation. The Proposal stems from Executive Order 14365, issued in December 2025, and addresses six priority areas including protecting children online, safeguarding small businesses, preserving intellectual property rights, defending free speech, accelerating AI development, and expanding AI-related workforce opportunities. The Proposal also pushes back against state efforts to assign liability to AI developers for third-party misuse, which could place a greater compliance burden on employers that deploy AI tools in hiring and other employment decisions. It is important to note that Congressional action on the Proposal remains uncertain and would be required before any of its recommendations result in new regulatory obligations for employers. In the meantime, employers should monitor legislative developments closely while continuing to build compliance strategies around existing state and local AI laws.
Treasury Department Proposes New Whistleblower Incentives
On April 1, 2026, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) published a proposed rule related to the Anti-Money Laundering and Anti-Money Laundering Whistleblower Improvement Act, establishing a whistleblower program offering incentives for individuals providing information about potential financial crimes. The proposal includes retaliation protections for employees who report violations to their employers. The public comment period is open until June 1, 2026, after which FinCEN will consider feedback before determining next steps in the rulemaking process.
White House Issues Second Proposal to Eliminate OFCCP
On April 3, 2026, the White House released its proposed fiscal year (FY) 2027 federal budget, which proposes to defund and eliminate the Office of Federal Contract Compliance Programs (OFCCP). This proposal mirrors a similar proposal made for FY 2026, which was ultimately rejected by Congress. The FY 2027 proposal would move OFCCP’s remaining statutory functions under Section 503 of the Rehabilitation Act and the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) to an expanded Office of Civil Rights, while attributing the reduction in OFCCP’s authority to Executive Order 14173, which abolished affirmative action requirements for federal contractors. Importantly, even if the proposal is adopted, federal contractors’ and subcontractors’ existing legal obligations under Section 503 and VEVRAA remain unchanged, as eliminating those obligations would require formal legislative action. Final funding decisions rest with Congress, so covered federal contractors or subcontractors should continue to maintain existing compliance programs and should monitor legislative developments for FY 2027.
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