Recapping the DOJ’s Evolving Policies on Corporate Enforcement and Compliance
This article recaps Department of Justice guidance since the Trump Administration took office in January. These are topics we’ve addressed in previous articles and alerts, and are presented here in summarized form. Upon taking office in January 2025, President Donald Trump and Attorney General Pam Bondi indicated a pro-business shift in its white collar enforcement priorities. A May 2025 Department of Justice memo stated, “[O]verbroad and unchecked corporate and white-collar enforcement burdens U.S. businesses and harms U.S. interests,” and “[n]ot all corporate misconduct warrants federal criminal prosecution”. The memo also called for an increased investigative pace of investigations to reduce the burdens such inquiries place on businesses. But a pro-business shift doesn’t mean the Administration or the DOJ doesn’t have enforcement priorities—and businesses need to be aware of these. Some of these are familiar, such as health care fraud, securities fraud, and market manipul...