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Warner Norcross + Judd LLP is a corporate law firm with over 230 attorneys serving clients in nine offices throughout Michigan. Among the largest law firms in Michigan, Warner works in virtually all areas of business law.

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Health Care Fraud and Procurement Fraud Lead DOJ’s Top 10 White Collar Enforcement Priorities as the Department Touts the Benefits of Effective Corporate Compliance Programs

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Matthew Galeotti, head of the Department of Justice’s (DOJ) Criminal Division <a href="https://www.justice.gov/opa/speech/head-criminal-division-matthew-r-galeotti-delivers-remarks-sifmas-anti-money-laundering">announced</a> in May that DOJ “is turning a new page on white-collar and corporate enforcement.” The same day, the Criminal Division circulated four guidance documents to federal prosecutors: (1) a <a href="https://www.justice.gov/criminal/media/1400046/dl?inline">memorandum</a> outlining DOJ’s white-collar enforcement priorities (the “Enforcement Priorities Memo”), (2) an updated <a href="https://www.justice.gov/criminal/media/1400036/dl?inline">memorandum</a> on the use of corporate monitors in Criminal Division matters (the “Corporate Monitor Memo”), (3) an <a href="https://www.justice.gov/d9/2025-05/revised_corporate_enforcement_policy_-_2025.05.11_-_final_with_flowchart_0.pdf">update</a> to the Criminal Division’s <a href="https://www.justice.gov/criminal/criminal-division-corporate-enforcement">Corporate Enforcement and Voluntary Self-Disclosure Policy</a> and (4) an <a href="https://www.justice.gov/criminal/media/1400041/dl?inline">update</a> to DOJ’s <a href="https://www.justice.gov/criminal/media/1400041/dl?inline">Corporate Whistleblower Awards Pilot Program</a>.

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DOJ’s Enforcement Priorities

DOJ identified 10 focus areas for federal investigation and prosecution, including, in brief:

Health Care Fraud. Health care fraud topped DOJ’s list, based on its belief that fraud is “rampant” in this space. Expect the government to mine claims data, scrutinize health care claims to public and private insurers and enforce the full complement of federal health care crimes, including submitting false claims, falsifying health care-related documents and interfering with health care audits and investigations.

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Controlled Substances Act. DOJ will continue to investigate health care professionals’ prescribing practices, particularly with respect to opioids and other controlled substances.

Procurement Fraud. DOJ also believes that fraud is rampant in government contracting, procurement and defense spending. DOJ encouraged whistleblowers to report such conduct by adding it to the list of tips that can lead to financial rewards under the Criminal Division’s Voluntary Self-Disclosure Policy.

Tariff, Customs and Sanctions Evasion. International trade and international corporate affiliations — particularly, with China and Chinese companies — are under increased scrutiny, with DOJ focusing on tariff, customs and sanctions evasion. DOJ encouraged whistleblowers to report this misconduct, too, by offering potential financial rewards for doing so.

Immigration Violations. To bolster its ongoing immigration enforcement efforts, DOJ created potential financial incentives for whistleblowers to report “[v]iolations by corporations of federal immigration law.”

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In all 10 of the listed corporate enforcement areas, DOJ made clear its intent to further pursue individuals — particularly, senior-level corporate officials. While DOJ’s guidance concerns criminal offenses, we expect the department to follow its policy of using all available civil, criminal, regulatory and administrative enforcement tools in each of these areas.

An Effective Compliance Program and Culture of Compliance Can Pay Dividends

A meaningful corporate compliance culture — steeped in an active compliance and internal reporting program — remains one of the best ways to stay ahead of government investigations. Galeotti commented on the additional benefits, under DOJ’s recent guidance of “making self-directed improvements and investing significant amounts in [corporate] compliance programs to solve problems internally and proactively.”

Corporate Monitors. Having an outside monitor review corporate practices and compliance can be expensive and time-consuming. DOJ’s guidance directs prosecutors to consider a company’s risk profile — the maturity of its internal controls, the routine testing of its compliance program and the existence of a culture of compliance — in determining whether an outside monitor will be a necessary component of any case resolution.

Voluntary Disclosure. DOJ published its memoranda, in part, to give companies “clear[er] guidance and certainty on the concrete benefits” of “self-reporting, owning up to criminal conduct, remediating, and cooperating with the Department.” These benefits include cases in which DOJ will decline to proceed altogether or offer more favorable settlement terms, like shorter non-prosecution agreements and a 75% reduction in criminal fines. These benefits are only available if, as an initial matter, a company knows about, addresses and discloses conduct without a “preexisting obligation to disclose the misconduct to the Department of Justice.”

Warner’s white collar defense attorneys have deep experience on both sides of government investigations — including in the areas that DOJ identifies as priorities — and are uniquely suited to help clients navigate the evolving enforcement landscape. Please contact Adam Townshend, Madelaine Lane, Chris Tracy, Charlie Quigg or your Warner attorney with any questions.

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Madelaine C. Lane

Charles R. “Charlie” Quigg

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DOJ Announces “New Page” in White Collar and Corporate Enforcement

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