This year, the Department of Justice (DOJ) increased its focus on white-collar crime enforcement in some areas, prioritized new areas, and shifted resources away from others. Many of these changes are reflected in Acting Assistant Attorney General Matthew R. Galeotti’s May 12, 2025, memorandum to the DOJ’s Criminal Division (Galeotti Memo), which highlighted 10 high-impact areas of white-collar crime for enforcement:[1]

1. Waste, fraud, and abuse, including healthcare fraud and federal program and procurement fraud that harm the public fisc.
2. Trade and customs fraud, including tariff evasion.
3. Fraud perpetrated through variable interest entities (VIEs), defined as “typically Chinese-affiliated companies listed on U.S. exchanges that carry significant risks to the investing public,” including, but not limited to, offering fraud, “ramp and dumps,” elder fraud, securities fraud, and other market manipulation schemes.
4. Fraud that victimizes U.S. investors, individuals, and markets, including, but not limited to, Ponzi schemes, investment fraud, elder fraud, servicemember fraud, and fraud that threatens the health and safety of consumers.
5. Conduct that threatens the country’s national security, including threats to the U.S. financial system by gatekeepers such as financial institutions and their insiders that commit sanctions violations or enable transactions by cartels, transnational criminal organizations (TCOs), hostile nation-states, and/or foreign terrorist organizations.
6. Material support by corporations to foreign terrorist organizations, including recently designated cartels and TCOs.
7. Complex money laundering, including Chinese Money Laundering Organizations and other organizations involved in laundering funds used in the manufacture of illegal drugs.
8. Violations of the Controlled Substances Act and the Federal Food, Drug, and Cosmetic Act, including the unlawful manufacture and distribution of chemicals and equipment used to create counterfeit pills laced with fentanyl, and unlawful distribution of opioids by medical professionals and companies.
9. Bribery and associated money laundering that impact U.S. national interests, undermine U.S. national security, harm the competitiveness of U.S. businesses, and enrich foreign corrupt officials.
10. As provided by the Digital Assets Deputy Attorney General (DAG) memorandum: (1) crimes involving digital assets that victimize investors and consumers; (2) crimes that use digital assets in furtherance of other criminal conduct; and (3) willful violations that facilitate significant criminal activity.

Enforcement Areas

1. Healthcare Fraud: DOJ’s Top Enforcement Priority
Healthcare fraud remains the DOJ’s top priority for white-collar crime enforcement. In May, the Galeotti Memo warned that “rampant healthcare fraud and program and procurement fraud drain our country’s limited resources.”

In June, the DOJ announced the largest healthcare fraud takedown in U.S. history, charging more than 300 individuals, including nearly 100 medical professionals, in schemes involving $14.6 billion in fraudulent claims. These cases highlight the DOJ’s “whole-of-government” approach, leveraging partnerships with agencies such as the U.S. Department of Health and Human Services Office of Inspector General (HHS-OIG), Centers for Medicare & Medicaid Services (CMS), and the Federal Bureau of Investigation (FBI).

In October, during a speech at a healthcare industry ethics and compliance conference, Acting Assistant Attorney General Galeotti reiterated that the DOJ is “keenly focused on healthcare fraud.”

Providers, compliance professionals, and others should expect increased scrutiny of billing practices and business arrangements. The DOJ’s Strike Force model—expanded this year to Chicago, Philadelphia, and Massachusetts, for a total of nine regions—partners prosecutors and investigators from the Criminal Division with local Assistant U.S. Attorneys to accelerate healthcare fraud investigations and prosecutions, often involving complex schemes and significant exposure. Robust compliance programs, regular audits, and whistleblower protections are essential.

Read more: DOJ’s Continued Focus on Healthcare Fraud and FCA Enforcement: What 2025 Means for Providers and Compliance Professionals; DOJ Announces Largest-Ever National Healthcare Fraud Takedown and Launches New Data Fusion Center

2. Trade Fraud Task Force: Cracking Down on Tariff Evasion
During the summer, it was reported that what is now called the Market, Government, and Consumer Fraud Unit—a group of highly specialized and experienced prosecutors in the Criminal Division that traditionally focused on financial fraud and market manipulation—would also focus on allegations of trade, tariff, and customs fraud. Shortly thereafter, the DOJ and the Department of Homeland Security (DHS) announced the formation of a Trade Fraud Task Force to combat tariff and duty evasion, smuggling, and related import violations.

The task force combines resources from the DOJ’s Civil and Criminal Divisions with DHS agencies such as U.S. Customs and Border Protection and Homeland Security Investigations. Enforcement will rely on statutes such as the Tariff Act of 1930, the False Claims Act (FCA), and criminal provisions under Title 18 of the U.S. Code. Companies found guilty of trade fraud could face severe penalties, including monetary fines and even prison sentences for individuals. We will further discuss enforcement of tariffs in our upcoming FCA year-end post.

Read more: DOJ and DHS Announce New Task Force to Counter Tariff Evasion; Importers Face Increased DOJ Scrutiny & Heightened Risk for Criminal Prosecutions

3. Paycheck Protection Program (PPP) Loan Fraud: Criminal Enforcement Continues
While not referenced in the Galeotti Memo’s areas of focus, COVID-19-era Paycheck Protection Program (PPP) loan fraud remains a focal point for DOJ white-collar enforcement. The DOJ’s approach in 2025 reflects a dual strategy: criminal prosecutions for egregious fraud, and civil actions under the FCA for misrepresentations in loan applications. We will also discuss FCA enforcement of PPP loans in the upcoming year-end post.

Criminal enforcement of PPP loan fraud has centered on charges such as wire fraud, bank fraud, aggravated identity theft, and conspiracy. Many cases involve alleged organized crime rings that submitted fraudulent applications with false payroll and revenue data. In one notable case, eight defendants pleaded guilty to wire fraud for defrauding PPP and other relief programs.

Read more: PPP Loan Fraud Enforcement Through Criminal Enforcement

4. Foreign Corrupt Practices Act (FCPA)
In June 2025, the DOJ issued new guidelines for Foreign Corrupt Practices Act (FCPA) investigations and enforcement, following an executive order that temporarily paused new FCPA actions to reassess their impact on American interests. The June memorandum directed prosecutors to limit undue burdens on U.S. companies operating abroad and to focus enforcement on conduct that directly undermines national interests.

Key priorities include targeting bribery schemes linked to cartels and transnational criminal organizations (TCOs), safeguarding fair competition for U.S. businesses, and advancing national security by prioritizing cases involving strategic sectors such as critical infrastructure and defense. Routine business practices and minor corporate courtesies are deprioritized, with the DOJ emphasizing substantial misconduct tied to individuals and sophisticated efforts to conceal bribery.

In October, Acting Assistant Attorney General Galeotti delivered remarks that the DOJ “will continue to enforce the FCPA firmly and fairly.” Also, as discussed in the next section, he emphasized the benefits of self-disclosure under the DOJ’s revised Corporate Enforcement Policy. Specifically, he highlighted an FCPA declination that occurred this year involving a company that self-disclosed its FCPA violations.

U.S. companies with a commercial presence abroad should maintain vigilance in their FCPA and anti-bribery compliance programs. High-risk countries for FCPA violations remain a particular focal point under the new policies.

Read more: DOJ Poised to Reboot FCPA Investigations and Enforcement

DOJ’s Revised Corporate Enforcement Policy
In May 2025, the Criminal Division announced significant revisions to its Corporate Enforcement and Voluntary Self-Disclosure Policy. The updated framework aims to incentivize companies to “come forward, come clean, reform, and cooperate” with government investigations. Under the revised policy, organizations that voluntarily disclose misconduct, fully cooperate, and implement timely remediation may receive substantial benefits, including declinations of prosecution or reduced penalties.

The DOJ’s message is clear: proactive disclosure is not just encouraged—it is rewarded. For compliance officers, this means ensuring internal reporting mechanisms are effective and that investigations are swift and thorough. The policy also emphasizes remediation, including disciplinary actions and enhancements to compliance programs. Companies that fail to act decisively risk harsher outcomes, including criminal charges and significant fines.

Read more: DOJ’s Revised Corporate Enforcement Policy in Action; Commercial Real Estate Developers Have New Incentives to Report Criminal Activity

Key Takeaways for 2025 and Beyond
The DOJ’s enforcement posture in 2025 reflects a broader trend toward aggressive, multi-agency investigations. Whether it is healthcare fraud, trade compliance, or pandemic-related programs, the government is leveraging criminal tools to maximize deterrence and recovery.

Going into 2026, companies will be well served by investing in proactive measures to strengthen compliance programs, such as regular risk assessments, employee training, and internal audits. When effective compliance programs reveal potential issues, experienced counsel can help investigate the allegations and determine next steps.

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[1] While local or regional criminal trends and other interests may lead some U.S. Attorneys to prioritize other areas of white-collar crime enforcement than their Criminal Division colleagues based in Washington, D.C., the Criminal Division’s major policies – like the Galeotti Memo – are usually developed with input from the Deputy Attorney General’s office and other senior DOJ officials, so they are a good indication of the Department’s overall enforcement goals.