On May 12, 2025, the U.S. Department of Justice ("the DOJ" or "the Department") unveiled its new playbook for prosecuting white-collar and corporate crime. DOJ announced enforcement priorities for the Criminal Division ("the Division") and introduced a host of changes designed to bring greater "focus" and "efficiency" to corporate investigations and prosecutions. These shifts are important to understand for any member of a corporate legal or compliance department running a corporate compliance program, facing a DOJ investigation, or laboring under an existing corporate integrity agreement or other corporate resolution. Moreover, the changing priorities provide opportunities for advocacy for companies that can claim harm to American business or consumer interests.
Criminal Division Head Matthew R. Galeotti issued a memorandum outlining the Division's enforcement priorities and policies, alongside a revised Corporate Enforcement and Voluntary Self-Disclosure Policy ("CEP"), a new Memorandum on the Selection of Monitors in Criminal Division Matters ("Monitor Memorandum"), and updates to the Corporate Whistleblower Awards Pilot Program ("Whistleblower Program").1 In parallel, Galeotti's delivered remarks at SIFMA's anti-money laundering and financial crimes conference, where he made clear that "the Criminal Division is turning a new page on white-collar and corporate enforcement."2 Stating that "most corporations and financial institutions want to play by the rules and...
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