New Corporate Enforcement Policies Focus on Transparency & Cooperation in White-Collar Crime Cases

Key Takeaways

• Self-Disclosure Benefits: Companies that voluntarily self-disclose misconduct and cooperate with investigations can now avoid criminal penalties.
• Streamlined Enforcement: The Criminal Division’s revised policy offers clearer, more predictable outcomes for companies willing to take responsibility for violations.
• Reduced Monitorships: The Department will impose fewer monitorships, focusing on those cases where they are necessary, to reduce the burden on businesses.
• Whistleblower Program Expansion: New priority areas in the corporate whistleblower program target fraud, sanctions violations, and support for criminal organizations.
• A New Approach: Galeotti emphasized that companies can now expect fairer, more efficient enforcement that prioritizes holding criminals accountable rather than punishing law-abiding businesses.

Deep Dive

At the 2025 SIFMA Anti-Money Laundering and Financial Crimes Conference in Washington, D.C., Matthew R. Galeotti, the head of the U.S. Department of Justice’s Criminal Division, unveiled significant changes to the Department’s approach to white-collar crime enforcement. In his speech, Galeotti underscored a shift towards increased transparency and fairness for businesses, with an emphasis on self-reporting and cooperation in exchange for more predictable outcomes in investigations and penalties.

The focus of these revisions, Galeotti explained, is to eliminate the punitive overreach that has historically deterred businesses from engaging in proactive compliance and reporting efforts. Highlighting the Department's role in tackling both violent crime and white-collar crime, Galeotti acknowledged the vital need for businesses to be partners in the fight against financial crimes such as fraud, sanctions evasion, and money laundering. He stressed that the Criminal Division is moving away from an overly adversarial approach that often led to drawn-out investigations and unfair outcomes for companies trying to navigate the complex regulatory landscape.

Turning the Page on Corporate Enforcement

"Unchecked fraud and financial facilitation are threats not just to our economy but to our national security," Galeotti said, noting that criminal actors—from cartels to hostile nation-states—frequently rely on financial institutions and corporations to execute their illicit activities. However, Galeotti also recognized that businesses are vital players in ensuring the integrity of the U.S. financial system. In this new enforcement framework, companies that voluntarily self-disclose wrongdoing, cooperate with investigators, and take remedial action will be offered clear and concrete benefits, including the possibility of a declination of charges.

In one of the most notable revisions, Galeotti announced that the Department’s Corporate Enforcement and Voluntary Self-Disclosure (CEP) policy has been simplified to make the process of self-reporting more transparent. Companies that meet specific criteria, such as full cooperation and no aggravating circumstances—will now be given the possibility of avoiding criminal charges altogether.

Corporate Self-Disclosure: The New Standard

Under the revised CEP, Galeotti emphasized that businesses must act quickly and transparently if they wish to benefit from these new guidelines. The message was that self-disclosure is now the key to receiving the most favorable outcomes in white-collar crime cases. Companies that come forward early and cooperate fully with investigations could avoid the costly, multi-year investigations that have historically burdened them.

"The days of lengthy, expensive investigations are over," Galeotti stated, reiterating that companies willing to take responsibility and demonstrate genuine effort to remedy any wrongdoing would not face unnecessary penalties or monitoring. The CEP revisions aim to simplify and streamline the process, making it easier for businesses to understand what is required and what they can expect in return.

For companies that may have delayed disclosing misconduct or whose violations have already been discovered by the Department, the revised policy also provides a clearer path to resolving such issues without heavy penalties. Galeotti explained that these companies could still benefit from reduced fines and limited monitorships, allowing them to focus on improving their internal controls rather than facing drawn-out compliance battles.

Reducing the Burden of Monitorships

As part of the Department's broader push for efficiency and fairness, Galeotti also announced changes to the Department's monitor selection policy. Recognizing that unrestrained monitorships can be costly and counterproductive, the new policy will ensure that monitors are only imposed when truly necessary and are scaled to fit the specific circumstances of the case. This approach aims to reduce the financial strain on businesses and ensures that resources are directed where they are most needed.

"Monitorships should not be a one-size-fits-all solution," Galeotti remarked. He emphasized that when imposed, monitors must be proportionate to the severity of the offense, and their scope must be focused to address the underlying issues effectively. The goal is to allow companies to reinvest in their own compliance programs while still holding them accountable for any wrongdoing.

Whistleblower Program Expanded

In addition to these changes, Galeotti outlined updates to the Department’s corporate whistleblower program, which now includes new priority areas for tips, such as violations related to procurement fraud, trade fraud, sanctions violations, and crimes associated with transnational criminal organizations. Whistleblowers who provide valuable information that leads to significant forfeitures will be eligible for awards under this revised program.

For compliance professionals, particularly those in Anti-Money Laundering (AML) and financial crime departments, Galeotti’s speech reinforced the critical role they play in identifying and reporting criminal activity. The Department’s new policies offer an opportunity for companies to collaborate more effectively with investigators, providing vital insights while ensuring that law-abiding businesses are not unduly punished.

"Now is the time for companies to be proactive," Galeotti concluded. "If you see something, report it. And in return, your company will be in a position to work with us to root out the real criminals and protect the integrity of our financial system."

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