Withdrawal from Criminal Participation

Withdrawal from Criminal Participation

Criminal participation does not always end simply because a person changes their mind.

A person may agree to participate in a robbery and later decide not to go through with it. A person may provide assistance to another criminal and then attempt to withdraw that assistance. A member of a conspiracy may leave the group before the planned offense occurs.

These situations raise an important question:

When does abandoning criminal participation protect a person from criminal liability?

The answer depends on the type of criminal participation involved.

In some circumstances, a timely and effective withdrawal may prevent liability for future conduct.

In others, withdrawal may have no effect on an offense that has already been completed.

This distinction is particularly important in conspiracy law. The Supreme Court held in Smith v. United States that withdrawal from a conspiracy does not erase the defendant’s completed participation in the conspiracy itself. Instead, withdrawal can terminate responsibility for certain later acts of co-conspirators. Cornell Legal Information Institute — Smith v. United States

The basic principle is therefore:

Withdrawal can stop future participation, but it does not necessarily erase past participation.

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1. What Is Withdrawal from Criminal Participation?

Withdrawal occurs when a person who has previously participated in criminal conduct affirmatively abandons that participation.

The exact requirements vary depending on the doctrine involved.

Withdrawal may arise in connection with:

• conspiracy;
• accomplice liability;
• aiding and abetting;
• solicitation;
• attempt;
• joint criminal enterprises;
• and other forms of collective criminal conduct.

Cornell’s Legal Information Institute describes withdrawal in the conspiracy context as leaving the conspiracy before the target crime has been committed, while noting that state laws differ regarding the consequences. Cornell Legal Information Institute — Withdrawal

Withdrawal is therefore not a single universal defense.

It is better understood as a collection of related legal principles concerning a person’s decision to abandon criminal participation.

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2. Withdrawal Is Not the Same as Never Participating

The first distinction is between withdrawal and absence of participation.

Suppose:

A never agrees to participate in a robbery.

A has not withdrawn from the robbery.

A simply never joined it.

Now suppose:

A agrees to help B rob a store but later decides to leave the plan.

That is a withdrawal issue.

This distinction matters because withdrawal presupposes that the person previously became involved.

The legal question is therefore:

Did the defendant first acquire criminal responsibility and then attempt to terminate the participation?

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3. Changing Your Mind May Not Be Enough

One of the most important rules is that a private change of heart may not constitute legal withdrawal.

Suppose:

A agrees to participate in a robbery.

The next day, A decides privately that the robbery is wrong.

A says nothing to B.

B continues with the plan.

Depending on the applicable doctrine, A may still be treated as a participant.

In Smith v. United States, the Supreme Court emphasized that withdrawal from a conspiracy requires affirmative action. Simply becoming inactive does not necessarily terminate the defendant’s membership in the conspiracy. Cornell Legal Information Institute — Smith v. United States

This produces an important principle:

Silence is not necessarily withdrawal.

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4. Why Affirmative Action Matters

Criminal conspiracies and joint criminal enterprises can continue even when one participant becomes inactive.

Suppose:

A helps create a criminal plan.

A later stops attending meetings.

A stops answering messages.

A does nothing else.

The remaining participants may reasonably continue operating under the assumption that A remains part of the enterprise.

For this reason, withdrawal often requires a definite act of disassociation.

The Supreme Court discussed this principle in United States v. United States Gypsum Co., where the Court approved an instruction requiring affirmative action demonstrating abandonment or disavowal of the conspiracy’s purpose. Cornell Legal Information Institute — United States v. United States Gypsum Co.

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5. Communication of Withdrawal

One traditional method of withdrawal is to communicate the decision to the other participants.

For example:

A tells B and C: “I am no longer participating. Do not expect me to provide the vehicle or any other assistance.”

Such a statement can provide evidence that A has affirmatively disassociated from the criminal undertaking.

In United States v. Gypsum, the Supreme Court discussed affirmative notification to other conspirators as one possible way of demonstrating withdrawal. Cornell Legal Information Institute — United States v. United States Gypsum Co.

The precise requirements vary, however.

A defendant cannot assume that simply announcing withdrawal will always eliminate liability.

Timing and the nature of the offense remain critical.

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6. Withdrawal May Also Involve Reporting the Crime

Another possible form of affirmative withdrawal is notifying law enforcement.

For example:

A joins a conspiracy to commit a robbery but later contacts law enforcement and provides information about the planned crime.

Depending on the applicable law, such conduct may constitute strong evidence of withdrawal.

The Supreme Court’s discussion in Gypsum identified disclosure of the illegal scheme to law enforcement as one possible affirmative act demonstrating disassociation. Cornell Legal Information Institute — United States v. United States Gypsum Co.

Reporting can be particularly significant because it does more than merely communicate a personal decision.

It actively opposes the criminal enterprise.

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7. Withdrawal Must Usually Be Timely

Timing is one of the most important aspects of withdrawal.

Suppose:

A agrees to help B commit a robbery.

A withdraws before the robbery occurs.

That may potentially protect A from responsibility for the future robbery under a doctrine recognizing effective withdrawal.

Now change the facts:

A helps B commit the robbery.

After the robbery is completed, A announces that A no longer wants to participate.

The announcement comes too late to erase A’s completed participation.

This illustrates the basic rule:

Withdrawal must occur before the relevant criminal liability becomes fixed if it is to prevent that liability.

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8. Withdrawal Does Not Erase a Completed Crime

Suppose A:

1. agrees to participate;
2. supplies the weapon;
3. helps plan the crime;
4. and the crime is completed.

A later says:

“I withdraw.”

That statement cannot ordinarily erase the completed criminal conduct.

The crime has already occurred.

Withdrawal is therefore fundamentally prospective.

It may affect what happens after the withdrawal, but it does not normally rewrite the past.

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9. Withdrawal from Conspiracy

Conspiracy provides one of the clearest examples.

A conspiracy is generally an agreement to commit an unlawful act together with the intent to achieve the agreement’s objective. Cornell Legal Information Institute — Conspiracy

Suppose:

A, B, and C agree to distribute illegal drugs.

Later, A decides to leave.

A’s withdrawal can terminate A’s participation in the continuing conspiracy for certain purposes, but it does not mean that A never joined the conspiracy.

This distinction was central to Smith v. United States.

The Supreme Court held that withdrawal:

• does not negate the defendant’s completed participation in the conspiracy;
• terminates the defendant’s liability for co-conspirators’ post-withdrawal acts;
• and can have important consequences for the statute of limitations. Cornell Legal Information Institute — Smith v. United States

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10. Withdrawal Does Not Necessarily Mean Innocence

This is one of the most important concepts in conspiracy law.

Suppose:

A joins a conspiracy.

A later withdraws.

A may still be guilty of the conspiracy itself.

The Supreme Court in Smith v. United States expressly distinguished withdrawal from complete exoneration. Withdrawal can terminate certain continuing consequences of participation without erasing the fact that the defendant joined the conspiracy. Cornell Legal Information Institute — Smith v. United States

Thus:

Withdrawal is not necessarily an admission that no crime ever occurred.

It may instead establish that the defendant ceased being responsible for subsequent conduct.

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11. Withdrawal and Co-Conspirator Crimes

This becomes particularly important when one conspirator commits additional crimes after another participant withdraws.

Suppose:

A and B agree to rob a bank.

A withdraws properly.

Afterward, B commits an additional offense in furtherance of the conspiracy.

The legal question becomes whether A can still be held responsible for B’s later conduct.

Under the federal approach described in Smith v. United States, effective withdrawal terminates a defendant’s liability for the post-withdrawal acts of co-conspirators. Cornell Legal Information Institute — Smith v. United States

This is one of the major practical benefits of effective withdrawal.

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12. Withdrawal and Pinkerton Liability

Withdrawal is especially important when analyzing Pinkerton liability.

Under Pinkerton doctrine, a conspirator may sometimes be responsible for substantive crimes committed by another conspirator when the required conditions are satisfied. Cornell Legal Information Institute — Pinkerton Liability

But if a defendant effectively withdraws from the conspiracy, the defendant may avoid responsibility for qualifying acts committed by co-conspirators after withdrawal.

The timing therefore becomes critical:

Before withdrawal:
Potential derivative responsibility.

After effective withdrawal:
Potential protection from later co-conspirator acts.

But again, withdrawal does not automatically erase liability for crimes already completed.

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13. Withdrawal from Accomplice Liability

Withdrawal can also arise outside conspiracy.

Suppose:

A agrees to help B commit a burglary.

A provides B with the necessary equipment.

Before the burglary occurs, A changes their mind.

A takes the equipment back and clearly informs B that A will no longer participate.

Depending on the jurisdiction, this may provide a basis for a withdrawal or renunciation defense.

The important issue is whether A has done enough to terminate the earlier assistance.

Merely deciding internally not to participate may be insufficient.

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14. Withdrawal May Require Undoing Earlier Assistance

A particularly important issue arises when the defendant has already provided assistance.

Suppose:

A gives B a weapon for use in a planned robbery.

A later changes their mind.

A tells B:

“I don’t want to participate anymore.”

But A leaves the weapon with B.

Has A actually withdrawn?

The answer depends on the applicable law.

Some legal frameworks require the defendant to take reasonable steps to neutralize or undo the assistance already provided.

Cornell’s discussion of renunciation describes criminal renunciation as abandoning participation and taking steps sufficient to neutralize assistance or material previously provided before the crime occurs. Cornell Legal Information Institute — Renunciation

This is an important distinction:

Stopping one’s own participation may not always be enough if one’s earlier assistance continues to facilitate the crime.

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15. Withdrawal vs. Renunciation

The terms withdrawal and renunciation are closely related but should not automatically be treated as identical.

Withdrawal

Generally concerns leaving an existing criminal participation relationship.

It is particularly important in conspiracy law.

Renunciation

Often refers to abandoning an intended or attempted crime before it is completed and, in some jurisdictions, taking additional steps to prevent its commission.

Cornell’s Wex definition describes renunciation in criminal law as abandoning participation before the crime takes place or attempting to stop other participants from proceeding. Cornell Legal Information Institute — Renunciation

The exact terminology varies by jurisdiction.

The safest approach is therefore to identify the particular doctrine being applied rather than assuming that withdrawal and renunciation have identical elements.

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16. Withdrawal Must Be Genuine

A defendant may not be able to claim withdrawal merely by performing a superficial act designed to create evidence of abandonment.

For example:

A tells B that A is withdrawing but secretly continues helping B.

That conduct does not represent genuine abandonment.

Likewise:

A tells B that A is finished but continues providing money, information, transportation, or equipment.

The surrounding conduct may demonstrate that A never truly abandoned the criminal enterprise.

Withdrawal is therefore a factual question as well as a legal one.

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17. Withdrawal and Mere Inactivity

Mere inactivity is particularly important in conspiracy cases.

Suppose:

A joins a conspiracy.

A then stops attending meetings.

A does nothing else.

That does not necessarily establish withdrawal.

In Smith v. United States, the Supreme Court emphasized that a conspirator’s responsibility can continue even when the conspirator becomes inactive, unless the defendant affirmatively withdraws. Cornell Legal Information Institute — Smith v. United States

This may seem counterintuitive, but it follows from the continuing nature of conspiracy.

The legal system does not necessarily interpret silence as a repudiation of the agreement.

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18. Withdrawal from a Completed Crime

Withdrawal is generally not available to erase a crime that has already been completed.

Suppose:

A and B commit a robbery.

Five minutes later, A says, “I’m out.”

The robbery has already occurred.

A cannot ordinarily transform the completed robbery into a non-crime by withdrawing afterward.

The same principle applies to other completed offenses.

Once all elements of the offense have been satisfied, a later decision to abandon participation generally cannot undo the offense.

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19. Withdrawal and Attempt

Attempt presents a more complicated situation because the crime may not yet have been completed.

Suppose:

A intends to commit a burglary.

A takes substantial steps toward committing it.

Before entering the building, A decides to stop.

Depending on the jurisdiction, A may potentially invoke a defense based on abandonment or renunciation.

But the requirements vary significantly.

Some legal systems distinguish between:

• voluntarily abandoning the criminal purpose; and
• stopping because circumstances make success unlikely.

For example:

A stops because A suddenly regrets the crime.

This is different from:

A stops because the police have arrived and arrest appears imminent.

The distinction between voluntary abandonment and abandonment caused by external circumstances can therefore become important.

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20. Withdrawal and Solicitation

Solicitation creates another interesting problem.

Suppose:

A asks B to commit a robbery.

B refuses.

A later tells B that A no longer wants the robbery to happen.

Depending on the jurisdiction, the solicitation offense may already have been completed when A made the request.

A later withdrawal may therefore not erase the completed solicitation.

However, withdrawal or renunciation may affect other potential liability depending on the statutory framework.

The broader principle remains:

A later change of mind does not automatically erase an offense whose elements have already been satisfied.

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21. Withdrawal and the Timing of Criminal Liability

The most useful way to understand withdrawal is through a timeline.

Stage One

The defendant has not joined the criminal enterprise.

No withdrawal issue.

Stage Two

The defendant joins or begins assisting.

Criminal participation may arise.

Stage Three

The defendant affirmatively abandons the participation.

Potential withdrawal.

Stage Four

The underlying offense occurs.

Late withdrawal may no longer prevent liability for the completed offense.

Stage Five

The defendant helps the offender escape afterward.

Potential separate post-crime liability.

This timeline demonstrates why the exact moment of withdrawal can be decisive.

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22. Withdrawal and the Burden of Proof

The burden of proving withdrawal can depend on the jurisdiction and the particular doctrine.

In Smith v. United States, the Supreme Court held that withdrawal from the conspiracy was an affirmative defense and that the defendant bore the burden of proving withdrawal in the circumstances presented. Cornell Legal Information Institute — Smith v. United States

This does not mean that defendants generally bear the burden of proving their innocence.

The prosecution must still prove the elements of the charged offense beyond a reasonable doubt.

But affirmative defenses can operate differently.

This distinction is important when analyzing criminal procedure and constitutional burdens of proof.

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23. Withdrawal and the Statute of Limitations

Withdrawal can also have consequences for the statute of limitations in conspiracy cases.

The Supreme Court in Smith v. United States explained that withdrawal starts the limitations clock for certain purposes because it terminates the defendant’s continuing participation in the conspiracy. Cornell Legal Information Institute — Smith v. United States

This does not mean withdrawal makes the underlying conduct lawful.

Instead, it determines the point after which the defendant is no longer treated as participating in the continuing conspiracy.

The distinction can become important when prosecution occurs years after the original agreement.

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24. Withdrawal Does Not Necessarily Protect Against Earlier Acts

Suppose:

A joins a conspiracy.

A participates in several criminal acts.

A later withdraws.

The withdrawal does not normally erase A’s responsibility for offenses completed before the withdrawal.

The defendant cannot use withdrawal as a mechanism to rewrite history.

This principle can be summarized:

Withdrawal is generally prospective, not retrospective.

It can terminate future participation without necessarily eliminating past liability.

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25. Effective Withdrawal vs. Ineffective Withdrawal

It can be helpful to compare the two.

Effective withdrawal

A:

• clearly abandons the criminal purpose;
• communicates the withdrawal where required;
• stops providing assistance;
• takes reasonable steps to neutralize previous assistance where required;
• and acts before the relevant offense or liability becomes fixed.

Ineffective withdrawal

A:

• privately changes their mind;
• remains available to the group;
• continues providing assistance;
• withdraws only after the crime is complete;
• or performs a symbolic act while secretly continuing participation.

The exact requirements depend on the governing law, but the distinction illustrates the central idea.

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26. Withdrawal Is Not the Same as Cooperation with Law Enforcement

Reporting the crime can be evidence of withdrawal.

But the two concepts should not automatically be treated as identical.

A person may withdraw from a criminal conspiracy without immediately becoming a government witness.

Conversely, someone may cooperate with law enforcement after committing a crime without thereby avoiding liability for the crime already completed.

Cooperation may affect:

• withdrawal;
• sentencing;
• immunity;
• plea negotiations;
• or other legal consequences,

depending on the circumstances.

These are separate questions.

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27. Withdrawal and Accomplice Liability for Later Crimes

Suppose:

A helps B commit a robbery.

After the robbery, B commits an unrelated assault.

A’s earlier participation in the robbery does not automatically make A responsible for every later offense committed by B.

This is another reason why withdrawal must be analyzed alongside the scope of accomplice liability.

The question becomes:

Was the later offense already within the criminal participation for which A became responsible?

If not, the prosecution needs another legal basis for attributing the later crime to A.

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28. Withdrawal and Joint Criminal Enterprises

In a joint criminal enterprise, one participant’s withdrawal can create a difficult factual question.

Suppose:

A, B, C, and D agree to commit a series of burglaries.

A later leaves.

B, C, and D continue.

The court may need to determine:

• when A joined;
• when A withdrew;
• how A communicated the withdrawal;
• whether A took steps to terminate participation;
• whether A’s earlier assistance remained available;
• which offenses occurred before withdrawal;
• which occurred afterward.

The chronology can determine the scope of liability.

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29. Evidence of Withdrawal

Because withdrawal often depends on conduct and timing, evidence can be critical.

Potential evidence includes:

• messages announcing withdrawal;
• emails;
• recorded conversations;
• testimony from co-participants;
• communications with law enforcement;
• returning weapons or equipment;
• cancelling financial arrangements;
• destroying one’s own access to criminal resources;
• warning intended victims;
• preventing further use of previously supplied assistance.

The evidence must be evaluated in context.

A statement saying “I’m out” can be important, but surrounding conduct may confirm or undermine its significance.

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30. A Practical Example

Suppose A, B, and C plan a robbery.

A agrees to provide the getaway vehicle.

Two days before the robbery, A changes their mind.

A sends B and C a message:

“I am no longer participating. I will not provide the vehicle.”

A then cancels access to the vehicle and tells the others not to use it.

B and C commit the robbery without A.

This is a strong factual basis for arguing effective withdrawal, assuming the jurisdiction’s legal requirements are satisfied.

Now change the facts.

A privately decides not to participate but says nothing.

A still leaves the vehicle available.

B and C use the vehicle during the robbery.

The withdrawal argument is much weaker.

The difference is not simply the defendant’s internal state of mind.

It is the defendant’s external conduct demonstrating genuine abandonment.

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31. Common Misunderstandings

Misunderstanding 1: “Changing your mind is always enough.”

False.

Withdrawal often requires affirmative conduct.

Misunderstanding 2: “Withdrawal means you are innocent.”

Not necessarily.

Withdrawal may terminate future liability without eliminating past liability.

Misunderstanding 3: “Stopping participation is always enough.”

Not necessarily.

Some doctrines require additional steps, particularly where the defendant has already provided assistance.

Misunderstanding 4: “Withdrawal can erase a completed crime.”

Generally no.

Withdrawal is ordinarily prospective.

Misunderstanding 5: “If I stop attending meetings, I have withdrawn.”

Not necessarily.

Mere inactivity may be insufficient in conspiracy cases.

Misunderstanding 6: “Withdrawal from conspiracy eliminates liability for everything that happened before.”

False.

Withdrawal generally does not erase completed crimes or the completed conspiracy itself.

Misunderstanding 7: “Withdrawal and renunciation are exactly the same.”

Not necessarily.

The terminology and legal requirements vary among jurisdictions.

Misunderstanding 8: “You can withdraw after the crime is completed.”

A later decision may affect other conduct, but it generally cannot undo criminal liability that has already attached.

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32. A Practical Framework for Analyzing Withdrawal

When confronted with a withdrawal problem, ask the following questions.

Question 1: What type of participation is involved?

Is the case about:

• conspiracy;
• aiding and abetting;
• attempt;
• solicitation;
• or another form of criminal participation?

Question 2: When did the defendant join?

Identify the point at which participation began.

Question 3: What did the defendant do before withdrawing?

Identify all assistance already provided.

Question 4: When did the defendant withdraw?

Timing is critical.

Question 5: Was the withdrawal affirmative?

Look for conduct demonstrating genuine disassociation.

Question 6: Was the withdrawal communicated?

Determine whether communication to co-participants or authorities is required under the applicable law.

Question 7: Was previous assistance neutralized?

If the defendant already provided equipment, information, access, or resources, determine whether the law requires reasonable steps to undo the assistance.

Question 8: Was the underlying crime already complete?

If so, withdrawal ordinarily cannot erase the completed offense.

Question 9: What happened after withdrawal?

Determine whether co-participants committed additional crimes afterward.

Question 10: What does the applicable jurisdiction provide?

Withdrawal doctrines differ significantly among jurisdictions.

This framework helps separate the critical questions of timing, conduct, intent, and legal consequence.

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33. The Deeper Principle

Withdrawal doctrine reflects an important tension in criminal law.

On one side, the law wants to discourage people from joining criminal enterprises.

On the other, the law may want to encourage people who have joined such enterprises to leave before further harm occurs.

If withdrawal were impossible under all circumstances, a person might have little legal incentive to abandon the criminal plan once participation had begun.

But if withdrawal automatically erased all prior liability, defendants could participate in serious crimes and attempt to escape responsibility simply by announcing that they had changed their minds.

The law therefore seeks a middle ground.

Abandonment can matter, but timing and conduct matter too.

This balance is especially visible in conspiracy law and in doctrines of renunciation and abandonment.

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Key Takeaways

• Withdrawal from criminal participation concerns a person’s affirmative abandonment of previously undertaken criminal participation.
• Withdrawal is different from simply never joining a criminal enterprise.
• A private change of heart may be insufficient.
• Mere inactivity may not establish withdrawal, particularly in conspiracy cases.
• Effective withdrawal generally requires some affirmative conduct demonstrating disassociation.
• Communication to co-participants or law enforcement may be important.
• Where previous assistance has been provided, some jurisdictions require steps to neutralize or undo that assistance.
• Withdrawal generally must occur before the relevant criminal liability becomes fixed if it is to prevent liability for future conduct.
• Withdrawal does not ordinarily erase completed crimes.
• In conspiracy law, withdrawal does not necessarily erase the completed conspiracy.
• Smith v. United States established that withdrawal can terminate liability for post-withdrawal acts of co-conspirators while leaving the defendant guilty of the conspiracy already committed.
• Withdrawal can affect the statute of limitations in conspiracy cases.
• Withdrawal and renunciation are related but distinct concepts.
• The exact requirements vary significantly by jurisdiction and offense.
• The central principle is that withdrawal is generally prospective rather than retrospective.

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Frequently Asked Questions

What does withdrawal mean in criminal law?

Withdrawal generally means affirmatively abandoning participation in a criminal enterprise after previously joining or assisting it.

Is changing your mind enough?

Usually not by itself. Depending on the doctrine, the defendant may need to take affirmative steps demonstrating genuine withdrawal.

Can withdrawal erase a crime that has already occurred?

Generally no. Once the elements of a crime have been completed, a later withdrawal ordinarily cannot erase the completed offense.

What is withdrawal from conspiracy?

It is the affirmative abandonment of participation in an existing conspiracy. Under federal law, effective withdrawal can terminate responsibility for later acts of co-conspirators but does not erase the defendant’s completed participation in the conspiracy.

Does stopping participation automatically constitute withdrawal?

Not necessarily. In Smith v. United States, the Supreme Court emphasized that affirmative withdrawal is required in the conspiracy context.

Does withdrawal have to be communicated?

The requirements vary by jurisdiction. Communication to co-conspirators or law enforcement can provide important evidence of affirmative disassociation.

What if I supplied a weapon and then changed my mind?

Simply changing your mind may not be enough. Depending on the jurisdiction, you may need to take reasonable steps to retrieve or neutralize the assistance previously provided.

Is withdrawal the same as renunciation?

Not always. Renunciation often refers to abandoning an intended or attempted crime before completion, while withdrawal is particularly important in the context of ongoing participation such as conspiracy.

Can someone withdraw after the crime is completed?

A person can certainly cease further participation, but that generally does not erase criminal liability for the completed offense.

Why does the law recognize withdrawal?

Withdrawal doctrine can encourage people to abandon criminal enterprises and prevent future harm while preserving responsibility for criminal conduct that has already occurred.

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Conclusion

Withdrawal from criminal participation demonstrates that timing matters enormously in criminal law.

A person who joins a criminal enterprise is not necessarily trapped forever. The law may recognize a genuine and timely decision to abandon participation, particularly when the defendant takes affirmative steps to communicate and demonstrate that decision.

But withdrawal is not a legal time machine.

It generally cannot transform completed criminal conduct into lawful conduct. A person who has already committed a crime, or whose participation has already completed an offense, cannot ordinarily erase that liability simply by announcing a change of heart afterward.

The distinction is especially important in conspiracy law. As Smith v. United States demonstrates, withdrawal can terminate a conspirator’s responsibility for certain post-withdrawal conduct while leaving intact the defendant’s responsibility for the conspiracy already joined. Cornell Legal Information Institute — Smith v. United States

The central lesson is therefore:

Withdrawal can stop future participation, but it does not necessarily erase the past.

Criminal law uses that principle to balance two objectives: holding people responsible for their own criminal conduct while giving participants a meaningful opportunity to abandon criminal enterprises before additional crimes occur.