On May 12, 2025, Matthew Galeotti, the Head of the U.S. Department of Justice's Criminal Division, sent a memo to all criminal division personnel highlighting the focus areas of the division for white-collar crime. The memo included a list of "high-impact areas" that the division will prioritize investigating and prosecuting. Trade and customs fraud, including tariff evasion, was second on the list. The DOJ also revised its Corporate Whistleblower Awards Pilot Program and added "trade, tariff, and customs [...]

On May 9, 2025, President Trump issued Executive Order No. 14294, "Fighting Overcriminalization in Federal Regulations" (EO), which reinforces the administration's deregulatory agenda. While sweeping in scope, the EO has immediate and concrete implications for companies facing potential criminal exposure under federal environmental laws. The practical result may be fewer but more severe environmental prosecutions, centered on egregious, intentional misconduct. Focusing on Intent The EO declares that "criminal enforcement of criminal regulatory violations is disfavored." [...]

On May 12, 2025, DOJ Criminal Division Head Matthew R. Galeotti issued a "multi-faceted" white collar enforcement plan (Memorandum) in which he noted that unchecked and overbroad white-collar enforcement burdens U.S. corporate interests. Galeotti cautioned that prosecutors must avoid overreach that "punishes risk-taking and hinders innovation," and called for an appropriate balance between prosecuting criminal wrongdoing and minimizing burdens on American enterprise. The Memorandum identified 10 high-impact areas for the Criminal Division's focus.1 In its [...]