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Jun. 18, 2025

Assessing the Criminal Division’s New Enforcement Focuses

  • Megan Zwiebel
    Anti-Corruption Report
The anti-corruption and compliance bar has been in a state of uncertainty since President Trump took office and paused enforcement of the FCPA. DOJ Criminal Division Head Matthew Galeotti brought a bit more solidity to the landscape when he announced that, going forward, the Criminal Division will prioritize cases in 10 “high-impact” areas. There is some overlap between the 10, and they can be consolidated into five broad categories: (1) healthcare fraud; (2) trade compliance; (3) financial crime (particularly crimes that relate to China); (4) crimes involving cartels, transnational criminal organizations and foreign terrorist organizations; and (5) bribery and corruption. This article assesses the impact of the new priorities. See our two-part series on the FCPA Executive Order: “The Future of U.S. Enforcement” (Mar. 12, 2025), and “Staying the Course in the Face of Continued Risk” (Mar. 26, 2025).

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