In a pair of speeches last week, Acting Assistant US Attorney General Matthew Galeotti provided a glimpse into the US DOJ’s priorities for white-collar enforcement and the early results of some of its ambitious enforcement initiatives.
Together, AAG Galeotti’s remarks sent a clear message that the DOJ intends to aggressively investigate and prosecute white-collar offenses in line with the administration’s “America First” objectives—including health care fraud, procurement fraud, trade fraud, fraud on US financial markets and foreign corruption—and that the DOJ is serious about incentivizing whistleblowing and corporate self-disclosure.
First, in remarks at the Association of Certified Anti-Money Laundering Specialists Conference, AAG Galeotti identified “the key threats to the United States” that are “most relevant to the financial services industry”: cartels and transnational criminal organizations, particularly those operating in Mexico and the Western Hemisphere; Chinese money laundering organizations ("CMLOs"); and “rogue nation-states like North Korea and Iran.” AAG Galeotti described the DOJ’s efforts to combat those threats, including charging leaders of cartels and CMLOs and prosecuting money laundering and sanctions evasion, then moved on to the private sector’s role. “First and foremost,” AAG Galeotti said, “we want you to work cooperatively with us.” That means “encourag[ing] your institutions to contact us” upon spotting suspicious transactions or other red...
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