In remarks at SIFMA’s Annual Anti-Money Laundering and Financial Crimes Conference, Matthew Galeotti, Head of the U.S. Department of Justice’s Criminal Division, announced sweeping reforms to the Division’s white-collar enforcement framework. The new strategy emphasizes prosecutorial focus, regulatory efficiency, and enhanced incentives for corporate cooperation.
Galeotti underscored the Department’s core mission: protecting Americans from the most serious criminal threats, including drug trafficking, transnational organized crime, and white-collar offenses that erode market integrity and national security. “Unchecked fraud in U.S. markets and government programs robs hardworking Americans and harms the public fisc,” he said. “Illicit networks facilitate sanctions evasion by hostile states and terror regimes.”
Galeotti announced a formal redirection of white-collar enforcement efforts, stating that companies adhering to the law are critical to U.S. economic prosperity. “We are here to prosecute criminals, not law-abiding businesses,” he said.
The Criminal Division’s new White-Collar Enforcement Plan prioritizes:
• Targeting the most egregious frauds affecting individuals, government programs, and market systems
• Holding accountable the enablers of transnational crime, including those engaged in sanctions evasion and money laundering
• Streamlining investigations to minimize disruption to compliant businesses
Central to Galeotti’s address was the unveiling of a revised Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP). The policy clarifies that companies meeting core criteria—voluntary self-disclosure, full cooperation, appropriate remediation, and absence of aggravating factors—will now receive a declination rather than a presumption of one.
Companies with some aggravating circumstances may still qualify for leniency based on the totality of their cooperation and remedial efforts. The revised policy also introduces a simplified structure with a flow chart to enhance clarity for in-house counsel and compliance officers.
The Department also announced a recalibration of its corporate monitorship policy. Galeotti criticized previous practices as overbroad and inefficient, noting that excessive monitoring could stifle business innovation and misallocate compliance resources.
Under the new approach:
• Fewer monitors will be imposed
• Prosecutors must weigh the cost-benefit ratio of appointing a monitor
• Monitor mandates will be narrowly tailored and subject to biannual oversight and budget caps
“We will require that monitorship costs be proportionate to the company’s misconduct, size, and risk profile,” Galeotti said.
The DOJ’s Corporate Whistleblower Pilot Program has been updated to align with national enforcement priorities. New focus areas for whistleblower tips include:
• Procurement and federal program fraud
• Trade, tariff, and customs violations
• Immigration-related offenses
• Sanctions evasion, material support for terrorism, and cartel facilitation
Eligible whistleblower tips must lead to forfeiture to qualify for monetary awards.
Galeotti concluded by urging AML and financial crime professionals to serve as first responders in the detection and reporting of corporate misconduct. “Now is the time to report, remediate, and strengthen compliance to ensure American prosperity,” he said. “Never before have the benefits of self-reporting and cooperating been so clear.”
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