June 9, 2025
Client Alert: Department of Justice’s New White Collar Crime Focus
The Department of Justice’s Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime memorandum released on May 12, 2025, signals a shift in DOJ corporate criminal enforcement. The memorandum signals a shift from past DOJ directives and focus, recognizing that ”not all corporate misconduct warrants federal criminal prosecution,” that “prosecution of individuals, as well as civil and administrative remedies directed at corporations, are often appropriate to address low-level corporate misconduct and vindicate U.S. interests,” and that DOJ “must strike an appropriate balance between the need to effectively identify, investigate, and prosecute corporate and individuals’ criminal wrongdoing while minimizing unnecessary burdens on American enterprise.”