DOJ declines prosecution for USRA and Liberty Mutual

An examination of how two companies avoided prosecution through voluntary disclosure and cooperation with the DOJ

DOJ Declines Prosecution for USRA and Liberty Mutual

Under the Trump era the Justice Department signaled it did not want to prosecute corporations and public statements highlighted voluntary cooperation as a path to avoid charges. The University Space Research Association received a declination letter in April after disclosing a scheme in which an employee sold sensitive aviation software to a Chinese university. The employee, Jonathan Soong, later pleaded guilty and was sentenced to 20 months in prison. USRA reimbursed funds and cooperated with investigators, a posture the government noted as decisive.
Declination letters remain rare and by 2024 the department issued only five such letters. The other widely reported case was Liberty Mutual, where the insurer disclosed that some employees bribed public officials in India and returned 4.7 million in ill-gotten profits. DOJ officials credited proactive cooperation and suggested the new policy manual and a general push toward voluntary self disclosure may shape corporate behavior.

This pattern signals a shift in how accountability is pursued in white collar cases. Cooperation is not a free pass, but a factor that can greatly influence outcomes when a company acts quickly, discloses full facts, and takes corrective steps. Yet the approach also raises questions about consistency and the potential for political calculation to shape prosecutions rather than the facts alone.
For boards and managers, the lesson is clear: invest in robust compliance programs, document internal investigations, and be prepared for transparent disclosures when misconduct emerges. The DOJ policy emphasis on self-disclosure is likely to affect how executives assess risk and respond to misconduct.

Highlights

The road to accountability in corporate crime is evolving, rewarding openness while still demanding real reforms.