- within Food, Drugs, Healthcare and Life Sciences topic(s)
- in United States
- within Law Department Performance, Accounting and Audit and Criminal Law topic(s)
On September 19, 2025, Acting Assistant Attorney Matthew Galeotti gave a speech stating white-collar enforcement remains a priority for the Department of Justice's Criminal Division. This statement comes following President Trump's February Executive Order and the Division's subsequent enforcement guidelines. Galeotti stated that the Department is holding white-collar criminals accountable, and is "identifying, investigating, and prosecuting fraud and corruption, and we are doing so in an effective, focused, fair, and efficient manner."
Galeotti discussed the key priority areas for the Division - health care fraud, procurement fraud, market integrity, including crimes associated with Chinese variable-interest entities, and foreign corruption.
The Criminal Division's Health Care Fraud Unit continues to hold individuals and corporations accountable in record numbers, including the largest health care fraud takedown in U.S. history in June of this year. The Division announced "Operation Gold Rush," where they charged 29 defendants for their alleged role in transnational criminal organizations that submitted over $12 billion in fraudulent claims to U.S. health insurance programs. The Division also disclosed the first two corporate resolutions by the Health Care Fraud Unit in nearly a decade against Kimberly-Clark Corporation and Troy Health, Inc.
Galeotti also highlighted that it would pursue cases against those who harm American markets and investors – and the Division is investigating cases connected to foreign companies listed on U.S. exchanges, including variable interest entities (VIEs) that present risks to U.S. retail investors, whom they target using social media and messaging applications. The Division charged a co-CEO of a Chinese issuer traded on NASDAQ and a financial advisor who organized a "ramp and dump" scheme that placed nearly $80 million of freely tradable shares into the hands of co-conspirators. The Division seized assets from relevant brokerage accounts used by co-conspirators, sending a clear message that the Department is committed to disrupting the rampant exploitation of American retail investors by foreign actors.
This speech also included revisions to the Corporate Enforcement Policy (CEP), which include:(1) a course toward resolving corporate investigations without ongoing obligations, (2) fine reductions for cooperation and remediation; and (3) the factors that determine the form of a final corporate resolution. In other words, if companies voluntarily self-report, cooperate, and remediate, they will receive a declination from the DOJ.
Galeotti also discussed some recent Department updates in accordance with the CEP, including charging two Mexican businessmen with Foreign Corrupt Practices Act (FCPA) violations; resolving the Liberty Mutual investigation requiring Liberty Mutual to disgorge $4.7 million in profits; and securing the conviction of a U.S. businessman for his role in a 5-year scheme to bribe Honduran government officials to secure business for a Georgia-law enforcement uniform manufacturer in connection with a money laundering scheme.
Buchanan's white collar defense, compliance, and investigations practice group is ready, willing, and able to assist you and address any questions you may have regarding the Department's white-collar investigation and enforcement priorities.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
