AUTHOR: Kritin Sundaram
DATE: 20 May 2025
On May 12, 2025, Matthew Galeotti, Head of the US Department of Justice’s Criminal Division, released a watershed memo to all Criminal Division personnel, entitled “Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime” (the “Memo”). This document has major implications for legal and compliance professionals globally – it provides a focused, precise approach to the DoJ’s revised enforcement approach and offers direction on how corporations must handle investigations.
At its core, the Memo establishes three guiding principles:
- Focus: the elimination of unfocused fishing expeditions, and instead targeting “high-impact” areas that, according to Galeotti, pose significant threats to U.S. interests
- Fairness: consistent and proportionate enforcement action, with standardised processes that do not unfairly burden legitimate business activities
- Efficiency: an effort at accelerating investigative processes to provide swift resolution to cases and minimise any collateral business impact
As stated in the Memo, the DoJ is “turning a new page on white-collar and corporate enforcement,” recognising that “law-abiding companies are key to a prosperous America.”
To this extent, the Memo has outlined specific high priority areas that will receive heightened scrutiny:
- Healthcare fraud, particularly affecting government programs;
- Trade and customs fraud, evasion of tariffs, and import regulations;
- Fraud perpetrated through variable interest entities (VIEs);
- Fraud that victimises US investors (such as Ponzi schemes, elder fraud, and fraud that threatened the health and safety of consumers);
- Conduct that threatens US national security and finance systems, and the evasion of US sanctions or conduct that enables transactions by cartels, hostile nation states, and/or terrorist organisations;
- Material support to terrorism and terrorist organisations, including to cartels newly designated as terrorist organisations;
- Complex money laundering operations (with particular mention of Chinese money laundering organisations), including schemes involving illegal drugs;
- Violation of the Controlled Substances Act and the FDCA (including those chemicals and equipment used to manufacture fentanyl-laced pills and unlawful distribution of opioids);
- Bribery and money laundering that impacts US national interests, undermines national security, harms competitiveness of US businesses, and enriches foreign corrupt officials; and
- Fraud schemes involving cryptocurrencies and digital assets that victimise investors and consumers in furtherance of other conduct (and willful violations that facilitate significant criminal activity).
For organisations operating in these spaces, this explicit prioritisation has a direct influence on heightened scrutiny and the need for robust investigative capabilities.
Additionally, in what is perhaps the most significant operational change is the expansion of the DoJ’s Corporate Whistleblower Awards Pilot Program to cover six new areas:
- Violations related to cartels or transnational criminal organisations
- Federal immigration law violations
- Corporate material support of terrorism
- Corporate sanctions offenses
- Trade, tariff, and customs fraud
- Corporate procurement fraud
The Memo specifically warns that “a surge of whistleblower complaints is expected” and directs companies to “thoroughly address issues identified in previous hotline reports.” As such, organisations must now get ahead of the game, to be well prepared to handle the volume of ethics complaints in a prompt, precise, and highly efficient manner.
The Memo’s efficiency mandate is unambiguous. For organisations, this means:
- Traditional, siloed investigation approaches are now a liability
- Inefficient evidence gathering and review processes could lead to DoJ intervention
- Slow reporting and decision-making could undermine cooperation credit
- Poor whistleblower management could trigger external reporting
Organisations must assess their exposure in the 10 priority areas, revisit whistleblower protocols, and focus on the establishment of efficient, precise investigation methodologies.
LEIAA: A purpose-built solution for the Galeotti era
Built by investigators for investigators, LEIAA by Augmetec was designed to specifically address these challenges. As a single interface end-to-end Investigations Command Centre, LEIAA allows organisations to:
- Promote a transparent corporate culture and maintain trust with stakeholders by maximising LEIAA’s customisable ethics and compliance reporting, triage, and management tool to properly capture and assess ethics complaints in all of the newly prioritised areas
- Utilise superior document analytics, including state-of-the-art AI-powered document fraud detection and data analysis tools to focus on actual misconduct and rapidly find relevant information in documents
- Build in standardised, transparent processes that create defensible investigation trails, with investigation templates, smart workflows, and comprehensive audit trails. This directly aligns with Galeotti’s emphasis on fairness and proportionality in enforcement actions.
- Leverage focused automation, smart dashboards and comprehensive collaboration and reporting tools to dramatically eliminate administrative, non-efficient time, which accelerates decision making and enhances investigative efficiency. As the Memo emphasised, investigations that “linger for years” are no longer acceptable.
The Galeotti memo represents both a challenge and an opportunity. Organisations that align their investigation capabilities with the DoJ’s new mandate for focus, fairness, and efficiency will be best positioned to successfully navigate the expected surge in ethics complaints, identify issues in priority areas, and avoid costly independent monitors (which Galeotti directs should be imposed only when “necessary“).
In this new landscape, LEIAA’s single source of truth and game-changing integrated toolset provides the capabilities needed to turn these challenges into advantages—allowing organisations to conduct investigations with confidence, and with the focus, fairness, and efficiency that the DoJ now demands.
Contact us today to see how LEIAA can help you adapt to the new DoJ white collar enforcement priorities.
