Revisions to Department of Justice (DOJ) white collar enforcement policies provide enhanced incentives for voluntary self-disclosure and clarify the consequences of failing to disclose wrongdoing. At the same time, expanded whistleblower incentives mean that companies must be alert to a wider range of legal and regulatory risks. Companies should review their internal investigation, reporting and remediation processes in light of the changes in order to be positioned to take advantage of the new incentives and protect against new whistleblower risks.

On May 12, 2025, Matthew Galeotti, head of the DOJ’s Criminal Division, issued a memorandum to all division personnel outlining the division’s updated enforcement priorities. See our May 14, 2025, alert “In a New Memo, DOJ Outlines White Collar Crime Focus Areas and Prosecutorial Guidance.”

The memorandum announced significant changes to three cornerstone corporate enforcement policies:

• The Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP).
• The Memorandum on Selection of Monitors in Criminal Division Matters (Monitor Selection Policy).
• The Corporate Whistleblower Awards Pilot Program, which was put in place last year.

Galeotti emphasized that the DOJ is refocusing its efforts on the most egregious threats to U.S. interests, while seeking to provide greater fairness, efficiency and transparency in its dealings with law-abiding companies. The DOJ’s revised enforcement plan aims to further incentivize...

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