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US DOJ overhauls corporate enforcement: clearer declinations for self-disclosure, narrowed monitorships, and an expanded whistleblower programme focused on national security and financial crime

Published on: 16 May 2025

Published by a Law360 reporter
Legal News
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Article summary

The revisions signal a broader reset towards 'focus, fairness, and efficiency', highlighting the DOJ’s intention to collaborate with law-abiding companies rather than penalise them indiscriminately. This shift is intended to foster cooperation, not blanket punishment.

Galeotti detailed updates across three corporate enforcement frameworks:

  • a simplified voluntary self-disclosure policy;
  • stricter limits on corporate monitorships;
  • new whistleblower priorities linked to national security and financial crime.

Each change underscores the DOJ’s ongoing concentration on serious criminal conduct - especially links to cartels and other transnational criminal organisations, state actors, and fraud against Americans - while giving companies clearer incentives and guardrails to navigate enforcement.

As Galeotti put it, the mission is to prosecute criminals, not compliant businesses. Effective white-collar work, he noted, depends on focus, fairness, and efficiency - principles that will guide Criminal Division prosecutors going forward.

Together, the changes represent a wider recalibration towards 'focus, fairness, and efficiency' and reinforce the DOJ’s preference to work with lawful enterprises rather than punish them wholesale.

A clearer path to declinations for companies that self-disclose

At the centre of the DOJ’s new approach sits an updated corporate enforcement and voluntary self-disclosure policy...

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