DOJ Signals Renewed Prioritization of Corporate Enforcement with New Policies Regarding Voluntary Disclosure, Monitors, & Whistleblowers

On May 12, 2025, Matthew R. Galeotti, the head of the DOJ’s Criminal Division, gave a speech at SIFMA’s Money Laundering and Financial Crimes Conference that previewed subsequently issued policy changes impacting the Criminal Division. 

Specifically, the Criminal Division’s Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), the Corporate Whistleblower Rewards Pilot Program (WEPP), and monitorship considerations were changed in several ways. In sum, the Criminal Division is directing its prosecutors to provide companies more leeway in the types and forms of resolutions available, but continues to expect disclosure, cooperation, and remediation, and plans to utilize whistleblowers for more types of criminal conduct. Significantly, the Criminal Division will continue to review internal controls, compliance programs, and compliance culture in its enforcement. As Galeotti noted, “now is the time to report, remediate, and strengthen compliance to ensure American prosperity.”