In December 2025, Acting (then-Deputy) AG Todd Blanche announced that the DOJ would soon issue a single corporate enforcement policy (CEP) covering criminal cases Department-wide. The resulting “Unified CEP” has now been issued and closely resembles the DOJ Criminal Division’s Corporate Enforcement and Voluntary Self-Disclosure Policy as edited in May 2025. A key carve-out and confusion over the status of Southern District of New York guidance issued by U.S. Attorney Jay Clayton just two weeks earlier leave it unclear whether the Unified CEP is the one true policy for the DOJ. This first article in a two-part series analyzing the impact of the Unified CEP looks at just how “unified” the new policy is. The second article will examine how the Unified CEP might change the voluntary self-disclosure calculus for companies. See “Do the 2025 Changes to the DOJ’s CEP and Whistleblowing Programs Encourage Companies to Self-Report?” (Jul. 16, 2025).