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Liberty Mutual and BofA Securities: Two Declinations, Many Lessons
In 2025, the U.S. Department of Justice declined to prosecute Liberty Mutual and Bank of America Securities despite evidence of foreign bribery and market manipulation. This article examines both cases and explains how voluntary self-disclosure, full cooperation, timely remediation, and meaningful compliance enhancements led to favorable outcomes under the DOJ’s revised Corporate Enforcement and Voluntary Self-Disclosure Policy. It offers practical takeaways for companies seeking to reduce enforcement risk through proactive compliance and transparency.