The U.S. Department of Justice’s expanded push to get more companies to self-report criminal activity in return for leniency will require firms that wish to capitalize to act swiftly, despite the gravity of the decision, legal observers say.

Assistant Attorney General Kenneth Polite Jr., who rolled out the initiative in a speech at Georgetown University on Tuesday, said companies that wish to self-report must provide “extraordinary cooperation,” must already have effective compliance program and internal controls in place that enabled identification of the misconduct, and must self-disclose “immediately upon” becoming aware of the allegation of wrongdoing.

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