Anti-Corruption & Compliance Blog

When the U.S. Department of Justice (DOJ) announced its first-ever Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) on March 10, 2026, it promised a uniform framework intended to incentivize companies suspected of criminal misconduct (other than antitrust offenses) to voluntarily self-disclose, fully cooperate in investigations, and timely and appropriately remediate. Recent declinations show the DOJ keeping that promise.

On July 29, 2026, the DOJ’s newly created National Fraud Enforcement Division announced its most recent declination, involving Campus Eye Management Holdings LLC and its subsidiary (collectively, Campus Eye), which was suspected of healthcare fraud in New Jersey. According to the declination letter, Campus Eye’s founder and former CEO developed schemes to bill Medicare and other insurers for duplicative, medically unnecessary eye tests and paid illegal kickbacks for patient referrals. The scheme resulted in Campus Eye receiving approximately $3.7 million in improper payments.

Thanks to the CEP, Campus Eye secured the most favorable outcome available: a “Part I” declination. A Part I declination is a full declination of prosecution available to companies that:

1. voluntarily self-disclose to the appropriate DOJ component;

2. fully cooperate;
3. timely and appropriately remediate; and
4. present no aggravating circumstances related to the offense’s seriousness, pervasiveness, severity of harm, or corporate recidivism.

For Campus Eye, the declination allowed it to avoid criminal exposure. Although the company remained subject to disgorgement, it was required to pay only $1 million in victim compensation instead of the full $3.7 million gain because it demonstrated an inability to repay the full amount. Meanwhile, the DOJ is pursuing a seven-count indictment against Campus Eye’s founder for his alleged misconduct.  

Campus Eye is now the third company to receive a Part I declination under the DOJ’s CEP, demonstrating that the policy is operating as promised across the Department. This declination followed two earlier resolutions under the CEP:

• March 19, 2026: The Criminal Division’s Fraud Section granted the CEP’s inaugural Part I declination to Balt SAS, a French medical-device company, in a Foreign Corrupt Practices Act bribery matter.
• June 17, 2026: The National Security Division announced its first Part I declination involving Robert Bosch GmbH in an export-control matter concerning exports of products and software to China, ultimately requiring Bosch to disgorge $11.4 million in profits.

While Part I declinations enjoy much of the media attention, the CEP also offers incentives to companies that fall short of the Part I criteria. Companies that do not satisfy those requirements may find themselves in the CEP’s “near miss” tiers, Parts II and III, which offer meaningful fine reductions and less onerous terms. Appendix A to the CEP includes a flowchart depicting the decision-tree process for determining CEP applicability and whether a company’s actions could result in treatment under Parts I, II, or III.

Taken together, the Balt, Bosch, and Campus Eye resolutions show that the CEP is not just policy on paper. Across foreign bribery, export controls, and healthcare fraud, the DOJ has done what it said it would do by rewarding early disclosure and cooperation while pursuing the individuals responsible. For companies weighing whether to come forward, the incentives are now clearer.