Key Takeaways
- The Department of Justice’s 2026 White Collar Crime Enforcement Priorities explicitly target cryptocurrency fraud, health care fraud, and corporate compliance failures, with a renewed emphasis on individual accountability under the Yates Memo principles.
- Expect a dramatic increase in prosecutions under the Foreign Corrupt Practices Act (FCPA) and the Money Laundering Control Act of 1986, particularly for transactions involving shell companies and digital assets.
- New guidance from the Fraud Section mandates that companies must self-disclose misconduct within 120 days of discovery to qualify for declination or deferred prosecution agreements, a significant tightening from previous informal timelines.
- The DOJ’s 2026 priorities incorporate enhanced penalties under the Federal Sentencing Guidelines for offenses involving artificial intelligence, including the use of AI to automate fraud schemes or conceal financial transactions.