We have determined that there is insufficient evidence to bring charges against Spitzer for any offense relating to the withdrawal of funds for, and his payments to, the Emperors Club VIP ... In light of the policy of the Department of Justice with respect to prostitution offenses and the long-standing practice of this office, as well as Spitzer’s acceptance of responsibility for his conduct, we have concluded that the public interest would not be further advanced by filing criminal charges in this matter.