DOJ Announces 2026 White Collar Crime Priorities: What the Policy Shift Means for Defendants

Key Takeaways

• DOJ's 2026 priorities expand corporate criminal enforcement under the Yates Memo and the Justice Manual § 9-28.000, with heightened focus on individual accountability and compliance program effectiveness.
• New directives emphasize aggressive use of the False Claims Act (31 U.S.C. §§ 3729–3733) and the Foreign Corrupt Practices Act (15 U.S.C. § 78dd-1 et seq.), particularly in health care, government contracting, and international business sectors.
• Defendants face increased risk of parallel civil and criminal proceedings, as DOJ will now require voluntary self-disclosure within 120 days of detecting misconduct to qualify for declination under the Corporate Enforcement Policy.
• The policy shift codifies stricter scrutiny of corporate compliance programs under the Evaluation of Corporate Compliance Programs guidance (2023 update), making real-time remediation and cooperation credit harder to obtain without full factual admissions.