
Since 10 March 2026, one DOJ policy governs corporate self-disclosure in every criminal matter except antitrust. Its rewards go to companies that find problems first and report promptly, which takes capability built in advance.

FinCEN's final rule ended beneficial ownership reporting for US companies and US persons. Foreign reporting companies still file, banks still ask, New York has its own law, and buyers still want the chart.

The UK offence counts your whole group toward its size test and turns on where the fraud touches the UK, not where you are incorporated. A US group with UK staff, customers or agents should treat it as live.
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