From the U.S. Attrorneh:
U.S. Attorney’s Office For the Northern District of Illinois Announces First-of-Its-Kind Individual Self-Disclosure Program
CHICAGO — The U.S. Attorney’s Office for the Northern District of Illinois today announced the formation of a first-of-its kind Program that both encourages and incentivizes individuals to voluntarily report and/or self-report criminal wrongdoing for non-violent offenses and fully cooperate with the government in its investigation and any subsequent prosecution of other offenders.
The Individual Self-Disclosure Program applies exclusively to individuals and does not overlap with the Department of Justice’s Corporate Enforcement and Voluntary Self-Disclosure Policy of March 10, 2026. Any corporate disclosures will be governed by the DOJ’s Corporate Enforcement Policy.
.The U.S. Attorney’s Office implemented the Individual Self-Disclosure Program to provide greater certainty and equal-access transparency to individuals and their counsel as to what they can expect in exchange for their full, truthful, and complete reporting of criminal wrongdoing and subsequent cooperation.
Those who fully and voluntarily self-report criminal wrongdoing that is previously unknown to the government will have the opportunity to secure one of three tiers of potential benefits:
(1) letter immunity;
(2) a deferred or non-prosecution agreement; or
(3) criminal prosecution with substantial sentencing relief.
An individual who receives a deferred or non-prosecution agreement under the Program must agree to disgorge any proceeds from the criminal activity through forfeiture or other means and pay restitution to victims consistent with the individual’s role in the offense and applicable law.
The Office will maintain its prosecutorial discretion to determine on a case-by-case basis whether an individual who reports wrongdoing merits one of the three tiers of benefits.
As set out in the Program, among the factors that the Office will consider are
- whether the criminal conduct had previously been made public or was previously known to law enforcement;
- whether the individual disclosed the criminal conduct voluntarily and not in response to a government inquiry or imminent threat of disclosure or government investigation;
- the completeness and timeliness of the disclosure; and the individual’s role and participation, if any, in the wrongdoing.
There are additional considerations that the Office will factor in its assessment, as is outlined in greater detail in the Program.
The Program supersedes the Northern District of Illinois’s Individual Self-Disclosure Pilot Program for Organizational Misconduct announced on Sept. 16, 2024.
“One of the key hallmarks of effective leadership is constantly striving for progress and innovation,” said Andrew S. Boutros, United States Attorney for the Northern District of Illinois.
“When I began serving as the United States Attorney for the Northern District of Illinois on April 7, 2025, I embarked on a deep, root-cause analysis of what was working and what was not working in the Office.
“In fraud and other adjacent program areas, I determined fairly quickly that a complete overhaul of our self-disclosure program was needed.
“From there, I personally rolled up my sleeves and got to work reimagining a program that would lead to individual voluntary disclosures, be responsive to the defense bar and its concerns, protect the sanctity of prosecutorial discretion, and be fair and reasonable to individuals who make the difficult decision to come forward with information.
“Drawing upon some 25 years of experience in the criminal law field, including nearly ten years as Co-Chair of White Collar, eight years as a federal prosecutor handling sophisticated white-collar prosecutions, 16 years of teaching criminal law at the University of Chicago Law School, including debating self-disclosure policies with colleagues and thought leaders, as well as authoring some 160 articles and two books on various white-collar, corruption and adjacent topics, I put ‘fingers to keyboard’ on re-envisioning an individual self-disclosure program that not only works, but also comports with Administration priorities.
“For the first time in the Northern District of Illinois, individual wrongdoers now know upfront with transparency and much greater certainty whether and how they can be rewarded when they self-disclose wrongdoing, fully cooperate with our investigation, and remediate the misconduct. Incentivizing individuals to come forward and do the right thing will result in a better outcome for victims and a just result for the citizens of our District.
“Although we expect this new self-disclosure Program to substantially increase our intake of fraud and other adjacent investigations, make no mistake: our Office will continue to vigorously pursue criminals who elect to roll the dice and not come forward and self-report their criminal activities.
“The defense bar now has a unique tool at their disposable that we hope will be used with great frequency.
“As such, for those individuals who make the decision not to self-report, they should not expect to be treated nearly as favorably as those who turn the corner and take account of their criminal conduct.”
Individuals who wish to make a voluntary disclosure must complete this form and submit it to USAILN.WBP@usdoj.gov.
Although anonymous reporting is not allowed, a new, unique feature allows for attorneys to reach out as an initial matter to the Front Office of the Chicago U.S. Attorney’s Office to provide an attorney proffer of their client’s wrongdoing, role in the offense, and the other criteria and factors discussed in the Program. Attorneys can do this without identifying their client.
The Program is not available to individuals whose misconduct involved violence, the threat of violence, gun trafficking and firearm offenses, terrorism, drug trafficking, child exploitation, human trafficking, or any sex offense involving fraud, force, coercion, trafficking, or a minor victim.
Additionally, absent extraordinary or unique circumstances, elected federal, state, local, or foreign officials, and federal law enforcement officers, are not eligible to participate in the Program. Click here for a full list of the Program’s terms and conditions.
