Understanding the DOJ's Recent Corporate Enforcement Policy Changes

Society of Corporate Compliance and Ethics (SCCE)
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On May 12, 2025 the head of the Criminal Division at the US Department of Justice issued a memo to all Criminal Division personnel with the subject: Focus, Fairness and Efficiency in the Fight Against White Collar Crime.

To understand what the document means for compliance programs, we spoke with Amy Matsuo, leader for both Regulatory Insights and Compliance Transformation at KPMG. Overall, she sees the document as being good news for compliance programs. It reiterates the importance and value of See more +

On May 12, 2025 the head of the Criminal Division at the US Department of Justice issued a memo to all Criminal Division personnel with the subject: Focus, Fairness and Efficiency in the Fight Against White Collar Crime.

To understand what the document means for compliance programs, we spoke with Amy Matsuo, leader for both Regulatory Insights and Compliance Transformation at KPMG. Overall, she sees the document as being good news for compliance programs. It reiterates the importance and value of quickly finding and remediating violations.

The DOJ also outlines some very favorable terms for organizations that self-disclose. These can include a declination with no requirement to enter into a criminal resolution, a non-prosecution agreement and a 75% reduction in potential fines.

The Department of Justice will also be reviewing settlements that are already in place and may provide relief if the organization is found to have made substantial progress, has a reduced risk profile and self-reported.

This review is a part of an effort to revisit monitorships and to ensure the cost to organizations is justified.

The Department of Justice also shared where it will be focusing its efforts. Procurement and program fraud, trade violations, sanctions violations and support to foreign terrorist organizations will all be in the cross hairs.

Listen in to learn more about what the DOJ’s expectations are and what you should be doing to ensure your organization meets them. See less -

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