The Ministry of Justice refines the strategy for the disease of the employee

On May 12, Matthew G. Galeotti Matthew G. Galeotti stated a memo to all employees of the criminal department entitled “Focus, Fairness and Efficiency in the fight against crime in order to enforce the enforcement of criminals and persecution of crime priorities and guidelines for the persecution of crime priority for companies and white subjects in the new administration. If 10 shows priority areas for investigations and law enforcement, the company is revised by the company setting of the department and the voluntary self -revealing policy of companies in order to offer companies more incentives, and the preliminary views of “optimizing corporate investigations” with a focus on fairness and efficiency as well as a reduction in corporate surveillance ships.

Ten primary areas for investigations and law enforcement

The memo lists the following ten focus areas:

1. Fraud in healthcare;
2. Commercial and customs fraud, including collective bargaining;
3. Fraud by Vies (Vies (variable interest company);
4. Fraud that US investors such as Ponzi programs and investment fraud experiences;
5. Sanctions violations or behaviors that enable transactions through cartels, TCOS, hostile nation states and/or foreign terrorist organizations;
6. Provision of material support for foreign terrorist organizations;
7. Complex money laundering, including systems with illegal drugs;
8. Violations of the controlled substances and the FDCA (food, drug and cosmetics law);
9. Bribery and money laundering that influence the national interests of the United States, undermine the national security of the United States, damage the competitiveness of the US business and enrich foreign corrupt civil servants. And
10. Digital asset crimes, with high priority for cases in which cartels, TCOs, drug money laundering or dodging for sanctions are involved.

These 10 focus areas and the order in which you are listed on the priorities that are defined in the previously published enforcement commands and memos of the Trump government.[1]

In a broader sense, Galeotti described the priorities as efforts by Doj, “an appropriate balance between the need to effectively identify, examine and pursue the criminal misconduct of companies and individuals, while unnecessary stress for American companies is minimized.” Galeotti explained that “[t]The vast majority of the American company are legitimate companies that work to offer added value for their shareholders and quality products and services for customers. “[p]Rosescutors must exceed that punish the risk of risk and hinder innovation. “Galeotti also makes it clear that DOJ's lawyers should” be directed by three core provisions: (1) Focus; (2) Fairness; and (3) Efficiency. “He also indicated that the pilot program for corporate whistleblower Awards has been changed in the criminal division in order to iron out these primary focus areas.[2]

Emphasis on individuals and fortune to companies

Galeotti emphasized the focus of the criminal department on the persecution of people and the need to further consider the efforts of companies to remedy the actions of individual bad actors. Galeotti promised that the criminal department “would relentlessly examine these individual misconduct in order to fold them into account” and the revision of the enforcement of the company department and the voluntary self -revealing policy (CEP) in order to offer more opportunities for withdrawal in which it is determined for companies that estimate themselves to dispose of companies and completely. These revisions include shorter conditions for non -insurance and postponed law enforcement agreements, reduced corporate penalties as well as the limited use and the terms of use of corporate monitors.[3] Galeotti expressly instructed the review of all current agreements with companies to determine whether they should be terminated early. Doj has already started to completely end the agreements he set.

Tightening of corporate investigations

Finally, Galeotti emphasizes the need to minimize the unnecessary costs and disorders for US companies based on investigations by Doj and “maximize efficiency”.

More efficient examinations

The prosecutors will recognize the complexity and the frequent cross -border nature of the departments of the department, and are instructed to “take all reasonable steps in order to minimize the length and collateral effects of their investigations and to ensure that bad actors are quickly brought to court and the resources marched efficiently.” The deputy general prosecutor's office will pursue an investigation together with the corresponding section to ensure that they are “quickly completed”.

Restriction of corporate surveillance

Doj will only impose compliance monitorhips if it considers it necessary and has pointed out that if they are imposed, these surveillance ships should be “tightened”. Construction of the memorandum of an earlier administration,[4] On May 12, Doj published a memorandum about the selection of monitors in matters of the criminal department, which provides for the factors for the examination, whether a monitory is appropriate, and guidelines to ensure that a monitory is properly tailored to the “risk of recurrence” and the “unnecessary costs”. When examining the appointment of a monitor, the prosecutors must:

• Risk of recurrence criminal behavior that significantly influences the interests of the United States;
• Availability and effectiveness of other independent state supervision;
• Effectiveness of the compliance program and the culture of compliance at the time of the solution; And
• Ripe for the controls of the company and its ability to test and update its compliance program independently

The head of the responsible section and the deputy general prosecutor must approved all surveillance ships, and the memo contains additional details for the appointment and monitoring of the monitor and the selection process of the monitor.

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The current freezing of doj and the latest personnel reductions/ new allocations should not be seen as a sign that the crime of the white collar can thrive as part of the current administration. Rather, Galeotti's memo of May 12 solidifies the enforcement guidelines and priorities that the Doj has previously preview since the first day of the Trump administration, and offers more clarity about what to expect in the involvement with the criminal department and the focus of its now overlaid resources and to expect the focus. Companies should familiarize themselves with this memo and the corresponding updates related to whistleblower, company enforcement and self -developments and surveillance ships to ensure that companies adequately assess their risk profile, tackle potential misconduct and meet the government's expectations.

[1] See, e.g.Executive Order 14157, cartels and other organizations describe as a foreign terrorist

Organizations and specially designated global terrorists (January 20, 2025) (Cartels Executive Order);

Memorandum of the Attorney General, total removal of cartels and transnational criminals

Organizations (February 5, 2025) (Kartels und TCOS AG -Morandum) Executive Order 14209, enforcement of the law on the enforcement of foreign corrupt practices on further American economic and national security (February 10, 2025); Cartels and TCOS AG Memorandum.

2 See “Updates of the doj criminal division (part 2): The Ministry of Justice updates the pilot program for corporate criminate whistleblower awards”

[3] See “Updates of the Doj Criminal Division (Part 3): New reasons for companies to discover themselves, criminal behavior”

[4] March 7, 2008 Craig Morford Memorandum (combating the selection and responsibilities of a company monitor).