Key Takeaways
- In my 25 years as a federal prosecutor, I have never seen the DOJ place such an aggressive emphasis on corporate compliance programs and individual accountability in white collar enforcement, as reflected in the 2026 priorities.
- The Foreign Corrupt Practices Act (FCPA) and the Money Laundering Control Act (18 U.S.C. § 1956) will see renewed focus, particularly targeting cryptocurrency transactions and international bribery schemes involving foreign officials.
- Healthcare fraud under the False Claims Act (31 U.S.C. § 3729) and the Anti-Kickback Statute (42 U.S.C. § 1320a-7b) will be a top priority, with prosecutors directed to pursue both corporate entities and individual executives for alleged overbilling and kickback arrangements.
- Environmental crimes under the Clean Water Act (33 U.S.C. § 1251) and the Clean Air Act (42 U.S.C. § 7401) are now formally classified as white collar priorities, signaling a major expansion of traditional fraud enforcement into regulatory criminal prosecutions.