Extract to table

The disclosure must be made before the company faces an imminent threat of disclosure by a government agency, media outlet, whistleblower, or other external source

The disclosure must occur "reasonably promptly" after the company becomes aware of the misconduct

At the time of the initial disclosure, the company must provide all relevant facts known to it regarding the misconduct

The initial disclosure need not reflect the results of a completed investigation — the DOJ understands that internal investigations take time — but the company must share the substance of what it knows at the time and commit to providing rolling updates as the investigation progresses

The company must provide timely disclosure of all facts relevant to the wrongdoing at issue, including facts about the individuals involved in or responsible for the misconduct

The company must make timely production of all relevant documents, including documents located abroad