Matthew Galeotti on the LiMu Declination and What to Expect in FCPA Enforcement

In 2025, there have been significant changes in DOJ policies toward FCPA enforcement in particular, and white-collar enforcement in general, but case studies of how companies will be treated have been somewhat thin on the ground. Comments from a top DOJ official in September and October 2025 shed light on what enforcement might look like as this tumultuous year comes to a close. At both the Annual Pharmaceutical and Medical Device Ethics and Compliance Congress and in a speech given in New York City, Acting Assistant AG Matthew Galeotti, the current Head of the DOJ’s Criminal Division, touted Liberty Mutual’s August 2025 declination as an example of how the current DOJ plans to move ahead with enforcement and offered predictions on what to expect in the months to come. This article synthesizes his remarks. See “Zaglin Conviction Offers Insights on Individual Prosecutions in Trump 2.0” (Oct. 22, 2025).

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