DOJ Criminal Division Updates (Part 1): DOJ’s New White Collar Crime Enforcement Plan
On May 12, DOJ’s Criminal Division head, Matthew G. Galeotti, issued a memo to all Criminal Division personnel, entitled “Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime,” to “outline the Criminal Division’s enforcement priorities and policies for prosecuting corporate and white-collar crimes in the new administration.” The memo highlights 10 priority areas for investigation and prosecution, calls for a revision of the Division’s Corporate Enforcement and Voluntary Self-Disclosure Policy to provide increased incentives to corporations, and previews “streamlining corporate investigations” with an emphasis on fairness and efficiency as well as a reduction in corporate monitorships.
Ten Priority Areas for Investigation and Prosecution
The memo enumerates the following ten areas of focus:
Health care fraud;
Trade and customs fraud, including tariff evasion;
Fraud perpetrated through VIEs (variable interest entities);
Fraud that victimizes U.S. investors, such as Ponzi schemes and investment fraud;
Sanctions violations or conduct that enable transactions by cartels, TCOs, hostile nation-states, and/or foreign terrorist organizations;
Provision of material support to foreign terrorist organizations;
Complex money laundering, including schemes involving illegal drugs;
Violations of the Controlled Substances Act and the FDCA (Food, Drug, and Cosmetic Act);
Bribery and money-laundering that impact U.S. national interests, undermine U.S. national security, harm the competitiveness of U.S. business, and enrich foreign corrupt officials; and
Digital asset crimes, with high priority to cases involving cartels, TCOs, drug money-laundering or sanctions evasion.
These 10 areas of focus — and the order in which they are listed — echo the priorities laid out in the Trump administration’s enforcement-related executive orders and memos published to date.[1]
More broadly, Galeotti described the priorities as DOJ’s effort to “strike an appropriate balance between the need to effectively identify, investigate, and prosecute corporate and individuals’ criminal wrongdoing while minimizing unnecessary burdens on American enterprise.” Galeotti explained that “[t]he vast majority of American business are legitimate enterprises working to deliver value for their shareholders and quality products and services for customers” and therefore “[p]rosecutors must avoid overreach that punishes risk-taking and hinders innovation.” Galeotti also makes clear that DOJ attorneys “are to be guided by three core tenets: (1) focus; (2) fairness; and (3) efficiency.” He also directed the Criminal Division’s Corporate Whistleblower Awards Pilot Program be amended to reflect these priority areas of focus.[2]
Emphasis on Individuals and Leniency Toward Corporations
Galeotti emphasized the Criminal Division’s focus on prosecuting individuals and the need to further take into account the efforts put forth by corporations to remediate the actions of individual bad actors. Galeotti promised the Criminal Division would “investigate these individual wrongdoers relentlessly to hold them accountable” and directed the revision of the Division’s Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) to provide more opportunities for leniency where it is determined corporate criminal resolutions are necessary for companies that self-disclose and fully cooperate. These revisions include shorter terms for non-prosecution and deferred prosecution agreements, reduced corporate fines, and limited use and terms of corporate monitors.[3] Galeotti specifically has directed the review of terms of all current agreements with companies to determine whether they should be terminated early. DOJ has already begun terminating agreements it determined have been fully met.
Streamlining Corporate Investigations
Finally, Galeotti emphasizes the need to minimize the unnecessary cost and disruption to U.S. businesses due to DOJ’s investigations and to “maximize efficiency.”
More Efficient Investigations
While acknowledging the complexity and frequent cross-border nature of the Division’s investigations, prosecutors are instructed to “take all reasonable steps to minimize the length and collateral impact of their investigation, and to ensure that bad actors are brought to justice swiftly and resources are marshaled efficiently.” The Assistant Attorney General’s office will, along with the relevant Section, track investigations to ensure they are “swiftly concluded.”
Limitation on Corporate Monitorships
DOJ will impose compliance monitorships only when it deems them necessary and has directed that those monitorships, when imposed, should be “narrowly tailored.” Building upon a previous administration’s memorandum,[4] DOJ issued a May 12 Memorandum on Selection of Monitors in Criminal Division Matters, which provides factors for considering whether a monitorship is appropriate and guidelines to ensure a monitorship is properly tailored to address the “risk of recurrence” and “reduce unnecessary costs.” In considering the appointment of a monitor, prosecutors are to consider the:
Risk of recurrence of criminal conduct that significantly impacts U.S. interests;
Availability and efficacy of other independent government oversight;
Efficacy of the compliance program and culture of compliance at the time of the resolution; and
Maturity of the company’s controls and its ability to independently test and update its compliance program
The chief of the relevant section, as well as the Assistant Attorney General, must approve all monitorships, and the memo lays out additional details regarding the monitor’s appointment and oversight as well as the monitor selection process.
Takeaways
DOJ’s current hiring freeze and recent personnel reductions/reassignments should not be taken as a sign that white collar crime will be permitted to flourish under the current administration. Rather, Galeotti’s May 12 memo further solidifies the enforcement policies and priorities the DOJ has been previewing since day one of the Trump administration and provides more clarity on what to expect when engaging with the Criminal Division and where it will be focusing its now-more-limited resources. Companies should familiarize themselves with this memo and corresponding updates related to whistleblowers, corporate enforcement and self-disclosures, and monitorships to ensure companies are appropriately assessing their risk profile, addressing potential misconduct, and meeting government expectations.
[1] See, e.g., Executive Order 14157, Designating Cartels and Other Organizations as Foreign Terrorist
Organizations and Specially Designated Global Terrorists (Jan. 20. 2025) (Cartels Executive Order);
Memorandum from the Attorney General, Total Elimination of Cartels and Transnational Criminal
Organizations (Feb. 5, 2025) (Cartels and TCOs AG Memorandum) Executive Order 14209, Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security (Feb. 10, 2025); Cartels and TCOs AG Memorandum.
2 See “DOJ Criminal Division Updates (Part 2): Department of Justice Updates its Corporate Criminal Whistleblower Awards Pilot Program”
[3] See “DOJ Criminal Division Updates (Part 3): New Reasons for Companies to Self-Disclose Criminal Conduct”
[4] March 7, 2008 Craig Morford Memorandum (addressing selection and responsibilities of a corporate monitor).
A New Enforcement Blueprint: How the Department of Justice Is Re-Shaping Its Approach to Digital Assets, Anti-Money Laundering, and Financial Crime
The Department of Justice (“DOJ”) has launched an ambitious realignment of its financial crime strategy, issuing two key policy pronouncements during spring 2025. Taken together, Deputy Attorney General Todd Blanche’s April 7 Memorandum, Ending Regulation by Prosecution, and Criminal Division Chief Matthew R. Galeotti’s May 12 remarks at Securities Industry and Financial Markets Association’s (“SIFMA”) Anti-Money Laundering and Financial Crimes Conference announce a coordinated, top-down course correction that will reverberate across the digital-asset ecosystem and the broader financial sector. The initiatives narrow the DOJ’s focus to the most pernicious threats—particularly investor fraud, terrorism, fentanyl and narcotics trafficking, organized crime, and sanctions evasion—while simultaneously dialing back “regulation by prosecution” of lawful market participants. At the same time, the DOJ continues to offer incentives for voluntary self-disclosure and cooperation, streamlining the use of corporate monitors, and reinforcing the centrality of robust compliance programs.
1. April 7 Memorandum: From “Regulation by Prosecution” to Targeted Digital-Asset Enforcement
The April 7 Memorandum signals a departure from the prior administration’s approach, which often sought to graft traditional securities or commodities frameworks onto novel blockchain technology through criminal indictments. Emphasizing that “the Justice Department is not a digital assets regulator,” Deputy Attorney General Blanche instructed prosecutors to discontinue cases whose “principal effect” is to impose licensing or registration regimes on technology providers. In practice, this means:
Dropping charges premised on non-willful violations of money-transmission, Bank Secrecy Act (“BSA”), securities-registration, broker-dealer, or Commodity Exchange Act provisions.
Avoiding litigation over whether a digital token is a “security” or “commodity” when classic Title 18 offenses—wire fraud, mail fraud, money laundering—will suffice.
Shuttering the National Cryptocurrency Enforcement Team and reallocating those resources to United States Attorneys’ Offices pursuing higher-priority crimes.
What remains squarely in prosecutors’ crosshairs are cases in which individuals (i) steal or misappropriate customer assets, (ii) perpetrate investment frauds such as “rug pulls,” or (iii) deploy digital assets to facilitate other felonies. In line with clear priorities expressed by this administration, the policy expressly cites cartels, human smuggling networks, fentanyl suppliers, foreign terrorist organizations, and sanctions-evading regimes as prime targets.
2. May 12 Remarks: A Re-Imagined Anti-Money Laundering and Fraud Framework
Echoing the April 7 Memorandum’s investor-and-national-security focus, Matthew R. Galeotti, Head of the Justice Department’s Criminal Division, unveiled a an updated Corporate Enforcement and Voluntary Self-Disclosure Policy devoted to “the most urgent threats to our country, our citizens, and our economy.” Key features include:
Clarity and Carrots for Self-Disclosure. The Criminal Division’s revised Corporate Enforcement and Voluntary Self-Disclosure Policy now provides an automatic declination—rather than a mere presumption—for companies that (a) voluntarily self-report, (b) fully cooperate, (c) remediate promptly, and (d) have a case that lacks aggravating circumstances. Even when aggravating factors exist or the DOJ learns of misconduct first, a self-disclosing entity can still expect substantially reduced penalties, lighter terms, and no monitor.
Right-Sizing Monitorships. A new monitor selection protocol imposes fee caps, budget approvals, and biannual tri-partite meetings to ensure that the “benefits of the monitor outweigh its costs.” DOJ is reviewing existing monitorships for narrowing or early termination.
Enhanced Whistleblower Incentives. Qualifying whistleblowers whose information leads to forfeitures in priority areas—including sanctions evasion, cartel finance, and immigration-related fraud—may qualify for cash awards.
Collectively, these revisions aim to shorten investigative timelines, encourage early cooperation, and re-deploy prosecutorial bandwidth toward the highest-impact cases.
3. Compliance Expectations in the Digital Asset Arena
Although the DOJ’s rhetoric is conciliatory toward law-abiding innovators, the underlying statutory framework has not changed. Bank Secrecy Act (“BSA”)/anti-money laundering (“AML”) obligations, Office of Foreign Assets Control (“OFAC”) sanctions, and state consumer-protection statutes remain fully enforceable—and future administrations could revive aggressive federal prosecutions within the statutes of limitation. Consequently, digital asset exchanges, custodians, wallet providers, and related service firms should:
Maintain rigorous Know-Your-Customer (“KYC”) onboarding, ongoing customer due diligence, and transaction monitoring.
Implement blockchain-analytics solutions capable of tracing on-chain movements and generating actionable red-flag alerts.
Document decision-making around token listings, protocol upgrades, and smart contract deployments to demonstrate the absence of scienter if a regulatory violation is alleged.
Preserve detailed audit trails to facilitate rapid, credible cooperation should misconduct surface internally or via subpoena.
A strong compliance posture not only hedges against future prosecutorial pendulum swings but also positions a company to avail itself of the DOJ’s newly generous self-disclosure regime.
4. April 7 Memorandum: Digital Assets and Cartels
The April 7 Memorandum explicitly links digital-asset enforcement to the fight against cartels and transnational criminal organizations (“TCOs”). Executive Order 14157’s “total elimination” directive designates cartels as Foreign Terrorist Organizations and Specially Designated Global Terrorists, giving prosecutors expanded authorities to pursue their financial facilitators. The DOJ has identified several converging trends:
Cartel Finance and Money Laundering. Mexican and Central American cartels increasingly accept bitcoin, stablecoins, and privacy-enhanced tokens as payment for narcotics shipments and precursor chemicals sourced from China. Mixing services and cross-chain bridges enable rapid layering, complicating asset tracing.
Human Smuggling Networks. Digital wallets facilitate ransom payments and coordination along smuggling routes, often leaving only blockchain footprints instead of traditional bank wires.
Fentanyl Supply Chains. Illicit marketplaces use cryptocurrency to settle transactions for fentanyl analogues, with darknet vendors rotating addresses to frustrate interdiction.
Sanctions Evasion by State Proxies. Some TCOs act as intermediaries for sanctioned states, exchanging bulk cash for crypto, or vice versa, to skirt OFAC restrictions.
Under the April 7 Memorandum, prosecutors will prioritize seizing the wallets, tokens, and keys directly controlled by cartel members or their money-laundering nodes, while generally declining to pursue exchanges or custodians absent willful misconduct.
5. Practical Takeaways for Industry
Self-Evaluate and Disclose. The DOJ has made clear the steps and substantial benefits for coming forward and reporting wrongdoing. A robust internal investigation, promptly followed by voluntary disclosure, may secure a declination even where wrongdoing occurred.
Multi-Layered Enforcement. State regulators such as the New York Department of Financial Services may step into any perceived federal void. Parallel investigations by foreign authorities—especially under Europe’s MiCA regime—remain a possibility.
Align Culture with Compliance. The DOJ’s message is unmistakable: companies that view compliance as a strategic asset, not a cost center, will fare far better than those that treat it as a check-the-box exercise.
Conclusion
The DOJ’s 2025 enforcement reset recalibrates prosecutorial resources toward the actors and conduct that have been identified by the current administration to inflict the greatest harm on investors, markets, and U.S. national security. Digital asset businesses, financial institutions, and multinational enterprises should seize this moment to reinforce compliance frameworks, upgrade investigative capabilities, and cultivate a culture that encourages prompt self-reporting to mitigate criminal exposure.
DOJ’s Updated Enforcement Policy: A Game-Changer for Corporate America?
On May 12, 2025, the U.S. Department of Justice (DOJ) announced a major overhaul of its corporate enforcement policy, aiming to incentivize companies to voluntarily self-disclose misconduct. Titled “Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime,” the revised policy was introduced by DOJ Criminal Division Chief Matthew R. Galeotti and promises a “clear path to declination” for qualifying companies. This marks a strategic shift that could significantly alter how corporate entities approach disclosures, investigations, and compliance moving forward.
The policy outlines 10 priority areas that Galeotti identified as critical threats to U.S. interests. These include healthcare fraud, trade and customs violations, misuse of digital assets, and misconduct posing national security risks. Schemes such as Ponzi operations, tariff evasion, and fraud involving Variable Interest Entities (VIEs) are called out specifically for undermining market integrity and harming U.S. investors.
At the core of the revised Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) is a strengthened framework to promote corporate transparency. The new policy addresses longstanding concerns about balancing the incentives for disclosure with the need for fairness in enforcement. Under the updated approach, companies may avoid criminal resolutions entirely if they:
Voluntarily self-disclose misconduct before it becomes public or is discovered by the government;
Fully cooperate with DOJ investigations;
Timely remediate the misconduct to prevent recurrence; and
Have no aggravating factors, such as repeat offenses or involvement by senior leadership.
Galeotti urged companies to disclose early and openly, noting that “timing and transparency in disclosure will tilt the scales towards leniency.” Even in cases involving aggravating circumstances, the DOJ may still offer a declination. This will depend on the severity of those factors and the company’s cooperation and remediation efforts.
Companies that report misconduct in good faith—without knowing whether DOJ is already aware—can still receive substantial benefits, including:
Shorter resolution periods, with agreements potentially lasting less than three years;
Significant fine reductions, based on cooperation, remediation, and the strength of a company’s compliance program; and
Reduced reliance on corporate monitors, with narrower criteria for when monitorships are imposed.
This reflects a meaningful departure from prior policies, which often conditioned benefits on stricter timelines or broader disclosures.
Another notable shift is the DOJ’s recalibrated approach to corporate monitorships. Described by Galeotti as “narrowed in scope to focus on practicality,” the updated policy introduces more discretion in imposing or terminating monitorships. Key considerations include the seriousness of the misconduct, the likelihood of recurrence, the robustness of a company’s compliance program, and alternative oversight mechanisms such as regulatory audits.
For companies currently under DOJ monitorships, the revised guidelines could offer relief. Depending on a review of risk and compliance strength, existing monitorships may be shortened or scaled back. Organizations should assess their compliance infrastructure and explore whether they meet the revised standards for a reduction or termination of oversight.
The DOJ’s updated policy signals a new era—one that emphasizes fairness and efficiency while continuing to aggressively pursue high-priority white-collar crimes. The message to corporate America is clear: proactive transparency and strong compliance are not only encouraged—they may be the key to avoiding criminal liability altogether.
For companies operating in enforcement-priority sectors, the takeaway is urgent. Strengthen your compliance programs, prepare for timely and honest disclosures, and act decisively in the face of potential misconduct. The incentives for doing so have never been greater.
Complaint Need Not Allege Fraud, Misrepresentation, Or Deceit To Be “Based Upon” A Corporation’s “Fraud, Misrepresentation or Deceit”
In 2002, the California Legislature created the Victims of Corporate Fraud Compensation Fund as part of the Corporate Disclosure Act. See Victims of Corporate Fraud Fund. There are a number of conditions that must be met to receive a payout from the fund. One of these conditions is that the victim secure “a final judgment in a court of competent jurisdiction against a corporation based upon the corporation’s fraud, misrepresentation, or deceit”. Cal. Corp. Code § 2282. In a recently published decision a California Court of Appeal decided that this condition was met even though the victims had not actually alleged “fraud, misrepresentation, or deceit”.
In Alves v. Weber, 2025 WL 1379121, the plaintiffs were defrauded by a corporation that promised, but failed to provide, long-term health care and estate planning services. The plaintiffs successfully obtained a judgment from the bankruptcy court that expressly adjudged plaintiffs to be “the victims of misrepresentation that satisfies all the essential elements of the California tort of intentional misrepresentation” and awarded specific monetary damages against the corporation”. The plaintiffs then sought recompense from the Fund, but the Secretary of State denied their claims, stating:
The Applications have been denied because the Default Judgment issued by the United States Bankruptcy Court for the Eastern District of California . . . does not appear to be a qualifying judgment for corporate fraud for purposes of the [Fund]. Further, none of the three claims for relief alleged in the Complaint to Determine Non-Dischargeability of Debt (11 USC 523 & 727), upon which the Default Judgment was based, are a ‘cause of action . . . for fraud . . . ’. See California Corporations Code sections 2281(g) and 2288(b)(2).
The Court of Appeal disagreed, holding that the plaintiffs had indeed obtained a final judgment based upon the corporation’s fraud even though they had not specifically alleged fraud. In this regard, the Court noted that “[a]lthough styled as a request to determine nondischargeability of debt, petitioners’ complaint also sought ‘a judgment determining that the . . . essential elements of the California tort of intentional misrepresentation have been satisfied’”.
FCA’s Discretion Upheld in IRHP Redress Scheme Judicial Review
Timely insights into the design of mass consumer redress schemes
In R (All-Party Parliamentary Group on Fair Banking) v Financial Conduct Authority [2025] EWHC 525 (Admin), the High Court examined the FCA’s decision regarding the exclusion of certain customers from the scope of the voluntary Interest Rate Hedging Products (IRHP) redress scheme established in 2012, which was criticised in a subsequent independent review. The case contains important insights into the trade-offs involved in the design of such schemes, given the high likelihood that the FCA will soon be rolling out a redress scheme to deal with motor finance mis-selling.
Background
From 2010 onwards, large numbers of complaints began to be made about mis-selling of IRHPs alongside small and medium sized business loans. The IRHPs, which typically swapped floating for fixed interest rates, had become ruinously expensive for many bank customers after interest rates fell sharply during the 2008 financial crisis. Following supervisory intervention by the FSA (the predecessor of the FCA), a voluntary redress scheme was negotiated with various large banks in 2012. The scheme incorporated a “sophistication test”, which excluded customers that exceeded certain objective metrics or were otherwise sophisticated in the use of financial products from being eligible to receive compensation under the scheme for mis-sold financial products.
Subsequently the FCA committed to a review of its supervisory intervention on IRHPs by a leading King’s Counsel. That review concluded (among other things) that the FCA should not have excluded a subset of customers from the scheme via the sophistication test. The FCA disagreed with these findings and decided to take no further action to address that conclusion. The All-Party Parliamentary Group on Fair Banking challenged this exclusion by way of judicial review proceedings, arguing that the FCA’s decision was irrational and procedurally unfair due to a lack of proper consultation with stakeholders.
The FCA argued that it was on balance right (or at least not irrational) to agree the redress scheme incorporating the sophistication test for a number of reasons including that:
There was real urgency to provide prompt assistance to a large number of small businesses that were in distress and prone to going into insolvency as a result of payments required under their IRHPs.
In this context there were significant advantages to a voluntary scheme over use of the FSA’s mandatory s.404 redress powers, which would be slower and more complex to implement, and prone to protracted challenge from the banks involved.
There were reasons for concern that the evidential challenges to the FSA of bringing action to require redress could not be overcome, resulting in worse outcomes all round.
The scheme delivered fair outcomes for those within its scope and the FSA was entitled to prioritize those customers.
The incorporation of the sophistication test followed intensive and robust negotiation with the banks and necessarily involved the need to make trade-offs to achieve the best overall result possible. There was no reason to believe that a better outcome could have been negotiated voluntarily with the banks.
Ultimately the scheme led to c.£2.2 billion being paid in redress in respect of 20,206 IRHP sales, with costs to the banks of c.£920 million.
Court’s Findings
The High Court rejected the challenge to the manner in which the FCA had exercised its discretion not to seek to require further redress to be paid to sophisticated customers excluded from the voluntary scheme, holding that:
Rational Basis: The FCA had a rational basis for its decision. The bar for irrationality is a high one and it was not irrational for the FCA to disagree with the conclusions of the independent review on the basis of a reasoned consideration that it conducted. There was no presumption that a public body in the position of the FCA should follow the recommendations of the independent review absent a good, very good, or cogent reason.
No Duty to Consult: The FCA was not legally obliged to consult stakeholders before making its decision regarding the exclusion criteria.
Regulatory Discretion: The FCA’s actions were within the scope of its regulatory authority and aligned with its statutory purpose of consumer protection. The FCA is afforded a wide measure of discretion as to when and how it will intervene to address potential mis-selling, having regard to its statutory objectives, regulatory principles and regulatory priorities. It could not be said to have misunderstood or misapplied that discretion in acting as it did.
Implications
This judgment reinforces the principles that regulatory bodies like the FCA have broad discretion in designing and implementing redress schemes (whether voluntary or compulsory, especially when balancing regulatory priorities, and the need for timely action, against the complexities of individual cases. Its decisions in such circumstances will not be lightly overturned by the courts. The judgment also shines a light into the decision-making processes of the regulator and the trade-offs that are made when negotiating such schemes. Those insights are worth considering at a time when another mass consumer redress scheme in relation to motor finance mis-selling is highly likely in the coming months, the design of which will inevitably involve similar issues.
PA Legislature to Consider Opening Two Year Window for Time Barred Sexual Abuse Claims
On May 6, 2025, the Pennsylvania House of Representatives’ Judiciary Committee announced its approval of two separate bills that would open a two-year window for victims of sexual abuse to file civil lawsuits for claims that are currently precluded by the statute of limitations or sovereign immunity. Both bills will now advance to the full Pennsylvania House of Representatives for further consideration.
In 2019, Pennsylvania passed legislation that extended the civil statute of limitations for childhood sexual abuse cases, giving victims until they turn 55 years old to file claims. However, the 2019 law does not apply retroactively, leaving some victims without recourse because their claims were already barred by the statute of limitations. The new bills aim to close that gap once and for all by allowing all victims of sexual abuse to file claims during a two-year window.
The two bills are House Bill 462 and House Bill 464:
House Bill 462: This bill provides a statutory two-year window during which survivors of childhood sexual abuse could file previously time-barred civil claims. It would also waive sovereign immunity retroactively under certain circumstances, allowing survivors to file claims against state and local agencies.
House Bill 464: This bill calls for an amendment to the Pennsylvania Constitution establishing a two-year window for survivors to bring forward civil claims that were previously blocked due to expired statutes of limitations. The amendment also waives sovereign immunity retroactively under certain circumstances.
The Judiciary Committee’s approval of the two bills followed a hearing where advocates and legal experts offered testimony in support of the legislation. Despite bipartisan support for these proposals over the last several years, previous efforts to pass such legislation have failed for various reasons.
When announcing the approval of the bills, Tim Briggs, Pennsylvania State Representative and Chair of the House Judiciary Committee, said “These bills are about fairness, healing and restoring the rights of people who were silenced for far too long.” “We owe survivors the chance to be heard in a court of law, no matter how much time has passed.” “The Judiciary Committee’s action is a powerful statement that justice delayed does not have to mean justice denied.” “We are finally moving toward a day when all survivors have the chance to seek accountability and healing.”
A similar law was passed in New York in 2019, after which we saw an explosion of sexual abuse cases filed in that jurisdiction. If either of the new Pennsylvania bills become law in the coming months, we expect that an enormous amount of sexual abuse lawsuits will be filed within that two-year window. It is important to start preparing now for the rush of claims that we anticipate will be filed once this legislation is passed.
Beyond the Headlines: Key Medicaid and Health Policy Changes You May Have Missed
On May 11, the House Energy and Commerce Committee released a detailed legislative text and a section-by-section summary of a broad health package affecting Medicaid, the Children’s Health Insurance Program (CHIP), ACA marketplace plans, and Medicare pharmacy benefit manager (PBM) oversight.
While high-profile elements related to Medicaid — such as proposed changes to provider taxes, noncitizen coverage, and Medicaid expansion populations — are drawing significant media attention, the legislation also contains several under-the-radar but consequential policies.
Program Integrity:
The legislation includes multiple provisions aimed at improving data accuracy and curbing waste, fraud, and abuse in Medicaid. These measures target administrative loopholes that have led to inefficiencies and duplicate spending. While these baseline oversight functions existed in different formats, they will now be uniform and codified:
Dual Enrollment Prevention: Requires a system that prevent individuals from being enrolled in more than one state’s Medicaid program at the same time.
Quarterly Death File Checks for Providers and Enrollees: States must conduct quarterly checks of both beneficiary and provider records against the Social Security Administration’s Death Master File. While many states already run monthly enrollee checks — particularly in managed care programs — this provision adds providers to the review process, helping further prevent erroneous payments.
Monthly Termination Checks: States must perform monthly cross-checks to identify providers who have been terminated by HHS or other states. Those flagged will be automatically disenrolled from Medicaid. Although the ACA required disenrollment of terminated providers, this new monthly verification requirement strengthens enforcement.
Regulatory Delays:
The legislative package includes targeted rollbacks or delays of rules introduced under the Biden administration:
Staffing Standards Moratorium for LTC Facilities: Implementation of federal staffing mandates for long-term care facilities will be delayed until January 1, 2035.
Delay in Streamlining Medicaid & MSP Eligibility: Proposed changes to streamline eligibility determinations for Medicaid and the Medicare Savings Program (MSP) will be delayed until January 1, 2035.
Medicaid Enrollment Rule Delay: Delays implementation of the federal rule aimed at streamlining eligibility and enrollment processes for Medicaid, CHIP, and the Basic Health Program until January 1, 2035.
Importantly, despite these delays, the Medicaid access-to-care rules remain intact, signaling continued federal emphasis on strengthening access and equity in care delivery.
Out-of-State Provider Enrollment
A standout provision for providers is the requirement that states create a streamlined enrollment process for out-of-state pediatric providers in Medicaid and CHIP. This change eliminates duplicative screening processes and lowers administrative barriers, making it easier for qualified providers to serve children across state lines.
This is a notable win for pediatric specialists and facilities that frequently treat children referred from other states, especially those with rare or complex conditions, and a step forward in improving continuity of care for medically vulnerable children.
Medicaid DSH Cuts Postponed
The bill postpones the scheduled $8 billion in annual Medicaid Disproportionate Share Hospital (DSH) cuts, originally set to begin in FY 2026, to FY 2029. This extension offers critical financial relief for safety-net hospitals and allows states more time to prepare budget adjustments.
Additionally, Tennessee’s DSH funding — previously set to expire at the end of FY 2025 — is extended through FY 2028, ensuring continued support for the state’s uncompensated care system.
As the legislative process moves forward, stakeholders should monitor implementation timelines, particularly around the program integrity provisions, and begin preparing systems and staff for compliance with new federal mandates.
Beneficial Owner Disclosure Under the New York LLC Transparency Act
After a rollercoaster of activity related to the federal Corporate Transparency Act (CTA), the US Treasury Department (Treasury) announced on March 2 that it will not enforce any penalties or fines associated with beneficial ownership information reporting for US reporting companies.
See “Treasury Department Announces Suspension of Enforcement of Corporate Transparency Act Against U.S. Citizens and Domestic Reporting Companies” press release here.
In response, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule that revised the definition of “reporting company” to include only foreign entities (see 31 C.F.R. § 1010.380(c)(1), effective March 26). For those limited liability companies (LLCs) formed or authorized to do business in New York, however, the New York LLC Transparency Act (NY LLC Act) is still forthcoming and will require reporting similar in certain respects to what would have been required for such companies under the CTA.
On March 1, 2024, New York Governor Kathy Hochul signed into law the New York Senate Bill 8059, thereby amending the NY LLC Act originally passed on December 23, 2023 (New York Senate Bill 8059, signed by Governor Hochul subject to chapter amendment).[1] The NY LLC Act requires LLCs formed or authorized to do business in New York, to report their beneficial owners and company applicants to the New York Department of State. The following is a brief summary of some of the key provisions of the NY LLC Act, and the significant effect that has been produced as a result of the changes in certain federal CTA definitions to which the NY LLC Act is anchored.
Definitions
Many key terms under the NY LLC Act are defined by reference to the definitions under the CTA, such as “beneficial owner” (31 U.S.C. § 5336(a)(3)), “reporting company” (31 U.S.C. § 5336(a)(11)), “exempt company” (31 U.S.C. § 5336(a)(11)(B)), and “applicant” (31 U.S.C. § 5336(a)(2)). However, with respect to the definition of reporting company, under the NY LLC Act, a reporting company means only LLCs formed or authorized to do business in New York.
As noted above, FinCEN issued an interim final rule revising the definition of “reporting company” to include only entities that were formed under the laws of a foreign country. If the NY LLC Act is not also amended to undo the effect of the revisions issued by FinCEN, the NY LLC Act would appear to only apply to foreign (i.e., non-US) formed LLCs that are authorized to do business in New York and would not apply to LLCs formed in New York or in any other US state. Accordingly, the NY LLC Act will likely also need revisions, at least to its definition provisions.
Initial Beneficial Ownership Disclosure
As noted above, each reporting company is required to file a beneficial ownership disclosure with the New York Department of State. The disclosure must identify each beneficial owner of the reporting company and each applicant with respect to the reporting company. The information required to be disclosed follows: (a) full legal name, (b) date of birth, (c) current home or business street address, and (d) a unique identifying number from an acceptable identification document such as (i) an unexpired passport, (ii) an unexpired state driver’s license, or (iii) an unexpired identification card or document issued by a state or local government agency.
All beneficial ownership disclosures shall be submitted electronically as prescribed by the New York Department of State. As of the date of this article, there is no program on the New York Department of State’s website for the submission of the beneficial ownership disclosures. The NY LLC Act explicitly allows for such disclosures to be signed electronically.
Exempt Companies
An LLC formed or authorized to do business in New York will be exempt from having to file the beneficial ownership disclosure if it meets one of the 23 exemptions (or 24 exemptions, considering the interim final rule under the CTA) enumerated under the CTA (31 U.S.C. § 5336(a)(11)(B)), such as, securities reporting issuers, banks, credit unions, securities brokers or dealers, venture capital fund advisers, accounting firms, tax-exempt entities, and large operating companies. Each exempt company is required to electronically file an attestation indicating the specific exemption claimed and the facts on which the exemption is based. In addition, the attesting company is required to file an annual statement with respect to its exempt status, as will be further described below.
Date of Initial Reporting with the New York Department of State
Companies Formed Prior to January 1, 2026
Each reporting company formed or authorized to do business in New York before January 1, 2026 (the effective date) of the NY LLC Act must file its beneficial ownership disclosure with the New York Department of State no later than January 1, 2027. Each exempt company formed or authorized to do business before the effective date of the NY LLC Act must file its attestation of exemption with the New York Department of State no later than January 1, 2027.
Companies Formed on or After January 1, 2026
Each reporting company formed or authorized to do business in New York after the effective date must file the beneficial ownership disclosure no later than 30 days after the initial filing of articles of organization or application for authority to do business in New York. Similarly, each exempt company formed or authorized to do business in New York after the effective date must file the attestation of exemption no later than 30 days after the initial filing of articles of organization or application for authority to do business in New York.
Annual Reporting
Next, after the reporting company has filed its initial beneficial ownership disclosure or attestation of exemption, as the case may be, it is required to electronically file a statement annually confirming or updating the following; (1) their beneficial ownership disclosure information; (2) the street address of its principal executive office; (3) status as an exempt company, if applicable, and (4) such other information as may be designated by the New York Department of State.
Failure to File
If a reporting company fails to file the beneficial ownership disclosure, attestation of exemption or annual statement, as the case may be, for a period exceeding 30 days, the reporting company will be shown as past due on the records of the Department of State. If the reporting company fails to file the requested information for a period of two years, it will be shown as delinquent on the records of the Department of State. Further, the NY LLC Act authorizes the attorney general to assess a fine of up to $500 for each day the company is past due and/or delinquent. In addition, the New York Attorney General can bring an action to suspend, cancel, or dissolve any delinquent company.
With the revision of the definition of reporting company under the CTA to eliminate domestic US reporting companies from its scope, the fate of the NY LLC Act should be closely monitored. As noted above, the NY LLC Act specifically incorporates by reference certain definitions under the CTA. In light of the revisions made under the interim final rule issued by FinCEN, the New York Legislature may potentially be inclined to review these definitions and make changes to the NY LLC Act to counteract the effect of FinCEN’s interim final rule as it pertains to domestic (i.e., non-foreign) LLCs.
[1] New York Senate Bill 995-B (enacted December 22, 2023), as amended by Chapter Amendment on March 1, 2024 (Senate Bill 8059/Assembly Bill 8544).
Landmark Texas Supreme Court Case Finds No “Direct Liability” for Franchisor Arising Out of Franchisee Employee’s Actions
On May 2, 2025, the Texas Supreme Court reversed a Texas Court of Appeals’ decision that had affirmed a jury’s verdict finding a franchisor directly liable to the customer of a franchisee for actions undertaken by the franchisee’s employee. The Supreme Court found that the franchisor did not owe a duty to the franchisee’s customer. This is a major ruling in the ongoing developments regarding potential franchisor liability for actions by independently owned and operated franchisees and franchisees’ employees.
Texas Supreme Court Reverses Franchisor Liability Ruling in Massage Heights Case
In Massage Heights Franchising, LLC v. Hagman, the Texas Supreme Court held that the franchisor, Massage Heights, did not owe a duty of care to a customer of the franchisee-owned location. The customer was sexually assaulted by Mario Rubio, a licensed massage therapist hired by the franchisee, MH Alden Bridge, LLC, despite his criminal background. The customer sued Massage Heights and other parties, asserting claims of negligence and gross negligence.
The jury found all defendants negligent, found a negligent undertaking by Massage Heights, attributed 15 percent responsibility to Massage Heights, and awarded Plaintiff both actual and exemplary damages. The court of appeals reversed the exemplary damages award but otherwise affirmed the trial court’s judgment, concluding that Massage Heights owed a duty of reasonable care to customers at franchise locations as a matter of law due to its general control over franchisee’s operations. The court also found there was sufficient evidence that Massage Heights was negligent in failing to provide a list of disqualifying offenses to its franchisees and allowing MH Alden Bridge to hire Rubio despite his criminal background.
Franchisor Duty of Care Hinges on Specific Control Over the Activity that Caused the Injury
The Supreme Court of Texas reversed. It recounted that the question of whether a franchisor owes a duty to a customer of a franchisee turns on control. The Texas Supreme Court held that the Court of Appeals erred by evaluating the franchisor’s “general right to control” instead of assessing the “specific control over” the “alleged… defects that led to [the plaintiff’s] injury,” as required. Exxon Corp. v Tidwell, 867 S.W.2d 19, 23 (Tex. 1993). The analysis and control “must relate to the activity that actually caused the injury.” Coastal Marine Servs. Of Tex., Inc. v. Lawrence, 988 S.W.2d 223, 226 (Tex. 1999). The Court then analyzed whether Massage Heights had control over the injury-causing conduct, which it found to be the hiring of Rubio.
The Supreme Court evaluated both the franchisor’s contractual right to control and actual control from the record and found that Massage Heights did not control Rubio’s hiring and thus owed no duty to Plaintiff. The Court found (1) Massage Heights did not have a contractual right to control MH Alden Bridge’s hiring of Rubio as the Franchise Agreement made MH Alden Bridge “solely responsible for all employment decisions,” and (2) the jury failed to find MH Alden Bridge was subject to Massage Height’s actual control by conduct, and Plaintiff had not proven as a matter of law that Massage Heights actually controlled Rubio’s hiring or that its safety instructions unreasonably increased Plaintiff’s risk of injury. Therefore, there was no proof of control over the specific injury-causing conduct.
Franchise Agreements Play Critical Role in Determining Legal Responsibility
The Court focused much of its reasoning on the language of the parties’ franchise agreement. The Franchise Agreement between Massage Heights and MH Alden Bridge provided that MH Alden Bridge was an independent contractor with sole responsibility for all employment decisions, subject to two conditions: all massage therapists had to (1) be licensed by the State (of Texas), without any suspensions or licensing offenses reported and (2) undergo an oral interview, a practical interview and a background check by MH Alden Bridge’s selected third-party provider. The franchise agreement also stated that MH Alden Bridge had sole responsibility for customer safety and security on its premises as well as compliance with Texas laws regarding hiring, training and supervising therapists. It was not sufficient that Massage Heights provided guidance and advice about certain “standards, specifications, processes, procedures, requirements or instructions,” particularly through the Operations Manual.
The Court found that aside from Rubio’s own criminal intent, the only plausible proximate cause of the assault was MH Alden Bridge’s decision to hire Rubio, which Massage Heights did not control. Therefore, Plaintiff’s alternative argument that Massage Heights had a duty to refrain from entering into a franchise agreement with MH Alden Bridge also failed. Lastly, the Court found there was legally insufficient evidence to support a finding of negligent undertaking—when a defendant undertakes to render services it knows are for another’s protection—as the franchise agreement contractually assigned all safety responsibilities to MH Alden Bridge, and Massage Heights had no duty to “investigate the operations” of MH Alden Bridge and its owners.
New DOJ White Collar Priorities Focus on Health Care Fraud
On May 12, 2025, the U.S. Department of Justice’s Criminal Division released a new guidance memo on white-collar enforcement priorities in the Trump Administration entitled “Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime.”
In this memo, and the accompanying speech by Matthew R. Galeotti, the Trump Administration’s appointed Head of the Criminal Division, the DOJ reiterated its previously stated commitment to prosecuting illegal immigration, drug cartels, and transnational criminal organizations. For the first time in the new Administration, however, the DOJ clearly articulated new white-collar enforcement priorities, directing Criminal Division white-collar prosecutors to follow three core tenets: focus, fairness, and efficiency. As detailed below, the new memo sets forth the following three priorities:
1. Focus on High-Impact Waste, Fraud, and Abuse Harming Vulnerable Taxpayers
It should be no surprise that the administration is targeting actors that profit through “waste, fraud, and abuse.” The memo sets clear priorities for its prosecutors to investigate, listing as the #1 priority health care fraud and federal program and procurement fraud. The memo goes on to provide a top 10 list of “high-impact areas”, with “trade and customs fraud, including tariff evasion” as #2. Heavy focus is given to fraud perpetrated by foreign actors and conduct threatening U.S. national security. Also listed is fraud victimizing U.S. investors, including elder fraud and Ponzi schemes. Appearing as #8 on the list is violations of the Controlled Substances Act and the Federal Food, Drug and Cosmetic Act, including the creation of counterfeit pills laced with fentanyl and the “unlawful distribution of opioids by medical professionals and companies.”
The memo also prioritizes efforts to identify and seize assets that are the proceeds of offenses harming vulnerable victims by amending the DOJ Criminal Division’s Corporate Whistleblower Awards Pilot Program to reflect priority areas where whistleblower tips lead to forfeitures. These areas include criminal violations related to international criminal organizations, corporations violating federal immigration laws, corporate sanctions, and trade offenses, and other areas consistent with the Administration’s previously stated priorities.
2. Fairness in Prosecuting Corporations and Individuals
Consistent with the outlook of prior administrations, the DOJ clearly stated that its first priority is to prosecute individuals as opposed to corporations. The memo notes that individuals commit crimes often at the expense of corporate shareholders, employees, investors, and American consumers. The memo also states that “the Division’s policies must strike an appropriate balance between the need to effectively identify, investigate, and prosecute corporate and individuals’ criminal wrongdoing while minimizing unnecessary burdens on American enterprise.” The memo cautions that not all corporate misconduct warrants federal criminal prosecution and directs prosecutors to consider additional factors when determining whether to bring criminal charges against corporations, including whether the company reported its conduct to the DOJ; the company’s willingness to cooperate with the government investigation; and remedial actions taken by the company. The memo also states that “prosecutors should prioritize schemes involving senior-level personnel or other culpable actors, demonstrable loss, and efforts to obstruct justice.”
3. Conduct Efficient Investigations That Do Not Linger
The memo acknowledges that federal investigations into alleged corporate wrongdoing can be costly and intrusive for businesses, investors, and others, and where individuals impacted by a lengthy investigation often had no knowledge of or involvement in the conduct at issue. The memo also concedes that corporate investigations can disrupt a business’s day-to-day operations and cause reputational harm. To decrease the impact on business and commerce, prosecutors are now required to minimize the length and collateral impact of their investigations by working expeditiously to investigate cases and make charging decisions.
In addition, the DOJ is implementing policy changes that could be seen as more business friendly, such as stating that potentially costly corporate monitorships are disfavored and only to be imposed in limited circumstances and ordering a review of existing monitorships and agreements with companies. The memo also limits existing corporate resolutions to three years, except in exceedingly rare cases, with guidance to regularly assesses these agreements to determine if early termination is appropriate.
Although many of these changes have been anticipated in the months since the change of administration, the memo provides clarity and concrete priority areas for prosecution – as well as areas where DOJ will pull back federal oversight, such as monitorships.
Our next blog will discuss the newly revised Justice Manual provision 9-47.120 – Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy, which provides that “additional benefits are now available to companies that self-disclose and cooperate, including potential shorter terms” of deferred or non-prosecution agreements.
We will be monitoring additional developments in this area as the Administration continues to implement policy changes.
DOJ Adds Procurement Fraud, Tariff, Sanctions, and Immigration Violations to Whistleblower Program Priorities
On May 12, the Head of the Department of Justice’s Criminal Division, Matthew R. Galeotti, announced that the DOJ Whistleblower Program has added a number of priority areas for tips which align with current administration’s priorities.
According to Galeotti, the new priority areas are
“procurement and federal program fraud;
trade, tariff, and customs fraud;
violations of federal immigration law; and
violations involving sanctions, material support of foreign terrorist organizations, or those that facilitate cartels and TCOs, including money laundering, narcotics, and Controlled Substances Act violations.”
These areas were added to the official revised guidelines for the Department of Justice Corporate Whistleblower Awards Pilot Program.
“We have made changes to our corporate whistleblower program to reflect our focus on the worst actors and most egregious crimes,” Galeotti stated.
The DOJ Whistleblower Program was established in August 2024. While the program’s framework falls critically short of some proven best practices for whistleblower programs, it offers monetary awards to insiders who provide original information which lead to successful forfeitures.
When the DOJ announced its plans for the whistleblower program, then-Deputy Attorney General Lisa Monaco stated the program “would fill the gaps in [the] patchwork” of successful corporate whistleblower programs, such as those administered by the SEC, IRS and FinCEN.
The original subject areas of the DOJ Whistleblower Program, which remain in the revised framework, are:
“Violations by financial institutions, their insiders, or agents, including schemes involving money laundering, anti-money laundering compliance violations, registration of money transmitting businesses, and fraud statutes, and fraud against or non-compliance with financial institution regulators.
Violations related to foreign corruption and bribery by, through, or related to companies, including violations of the Foreign Corrupt Practices Act, violations of the Foreign Extortion Prevention Act, and violations of the money laundering statutes.
Violations committed by or through companies related to the payment of bribes or kickbacks to domestic public officials, including but not limited to federal, state, territorial, or local elected or appointed officials and officers or employees of any government department or agency.
Violations committed by or through companies related to (a) federal health care offenses and related crimes involving health care benefit programs, and (b) fraud against patients, investors, and other non-governmental entities in the health care industry.”
Notably, a wide range of misconduct which fall under the DOJ Whistleblower Program’s new priorities are covered under existing whistleblower programs. For example, government procurement fraud and trade, tariff, and customs fraud are covered by the False Claims Act, which is handled by the DOJ Civil Division (though related criminal actions can be taken). Sanctions evasion is covered under FinCEN’s AML and Sanctions Whistleblower Program.
Geoff Schweller also contributed to this article.
Continued Developments in the Anti-Bribery/Anti-Corruption Sector: A Potential Expansion of the International Anti-Corruption Prosecutorial Taskforce on the Horizon
There have been a number of developments in the anti-bribery/anti-corruption sector following the start of President Trump’s second term. First, on February 5th, Attorney General Pamela Bondi issued a memo titled, “Total Elimination of Cartels and Transnational Criminal Organizations” in which she instructed the Foreign Corrupt Practices Act (FCPA) Unit at DOJ to focus on “investigations related to foreign bribery that facilitate the criminal operations of Cartels” and Transnational Criminal Organizations (TCOs). She also suspended the requirement that the Fraud Section lead investigations involving the FCPA and Foreign Extortion Prevention Act if the investigation is into “foreign bribery associated with Cartels and TCOs.”
That memo was followed by President Trump signing Executive Order 14209 titled, “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security.” In that order, President Trump noted that FCPA enforcement has been “stretched beyond proper bounds and abused in a manner that harms” the U.S. He further explained that FCPA enforcement compromises the U.S.’s foreign policy goals, “the President’s Article II authority over foreign affairs,” national security, and the ability of the U.S. “and its companies gaining strategic business advantages.” President Trump ordered Attorney General Bondi to revise DOJ guidelines and policies related to the FCPA, require new FCPA investigations and enforcement actions to have Attorney General Bondi’s approval, review pending FCPA investigations and enforcement actions to ensure their compliance with the order, and identify whether any remedial actions are necessary. This order was accompanied by a fact sheet that echoed the points described above.
In response to the federal government’s shift with FCPA enforcement, states have indicated they may step up their bribery enforcement actions. For example, California’s Attorney General Rob Bonta issued a legal advisory “reminding businesses operating in California that it is illegal to make payments to foreign-government officials to obtain or retain business.” Attorney General Bonta explained that FCPA violations can be the basis for actions under California’s Unfair Competition Law. Similarly, the District Attorney for Manhattan shared that his office was exploring methods for taking on various enforcement priorities that the DOJ has indicated it will not be pursuing as heavily as it once did, including domestic bribery and corruption.
Internationally, the UK, France, and Switzerland announced the launch of the International Anti-Corruption Prosecutorial Taskforce. The taskforce includes (1) the UK’s Serious Fraud Office, (2) France’s National Financial Prosecutor’s Office, and (3) the Office of the Attorney General of Switzerland. Among other things, the taskforce announced its commitment to tackling “the significant threat of bribery and corruption and the severe harm that it causes.” The taskforce also noted that it would “invite other like-minded agencies” to join the taskforce’s efforts. To accomplish its goal, the taskforce identified four action items: (1) regularly exchanging “insight and strategy,” (2) “devising proposals for co-operation on cases,” (3) sharing best practices “to make full use of” the taskforce’s “combined expertise,” and (4) “seizing opportunities for operational collaboration.”
Last week, Jean-Francois Bohnert, the head of France’s agency tasked with bringing enforcement actions against, among other things, corruption, mentioned that other countries have contacted the taskforce to discuss their interest in potentially cooperating with the taskforce. Those countries included Germany, Italy, the Netherlands, Spain, and multiple unnamed countries in Latin America.
These developments have led some to question the trajectory of the FCPA enforcement landscape for the duration of the Trump administration. That said, speculation that FCPA enforcement would be relatively non-existent appears to be overstated at this point given that although the federal government has refrained from proceeding with some pending FCPA trials, they have proceeded with others. As for state enforcement actions in this area, it remains to be seen just how robust those actions can be given restrictions such as jurisdictional limitations and limited state resources (which are already stretched in numerous areas currently).
Given these considerations, the International Anti-Corruption Prosecutorial Taskforce is poised to have a significant impact on the anti-bribery/anti-corruption enforcement landscape. If additional countries join (which it appears that at least some number of countries may join or otherwise assist the taskforce), then the taskforce’s impact in this sector will be heightened. It would not be surprising to see the taskforce take on a role similar to the role the federal government held in prior years with respect to anti-bribery/anti-corruption investigations that encompass multiple countries. Companies should thus ensure they continue to maintain robust compliance programs, and properly functioning compliance programs are even more essential for those companies operating overseas.