DOJ Announces White Collar Enforcement Priorities And Revisions To Related Policies

I. Introduction

On May 12, 2025, Matthew Galeotti, the Head of the Criminal Division at the Department of Justice ("DOJ") issued a new white collar enforcement plan ("Enforcement Plan") titled "Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime." The Enforcement Plan sets out priorities and objectives that align with the Administration's already articulated "America First" priorities, such as boosting government efficiency by addressing fraud in U.S. markets and government programs, enforcing tariffs and prosecuting the distribution of narcotics.

The Enforcement Plan also introduces potentially meaningful process changes, including a focus on efficiency in government investigations, prioritizing the prosecution of senior-level conduct and narrowly tailoring the use of monitors. The announcement of the Enforcement Plan was accompanied by revisions to several recent DOJ policies, including the Criminal Division's Corporate Enforcement and Voluntary Self-Disclosure Policy and the Corporate Whistleblower Awards Pilot Program announced during the prior administration.

In this alert, we review the key aspects of the Enforcement Plan followed by the changes to existing DOJ policies on self-disclosure, monitorships and the whistleblower pilot program.

II. White Collar Enforcement Plan

The Enforcement Plan identifies ten areas of focus and names as top priorities investigating and prosecuting crimes involving waste, fraud, and abuse in U.S. markets and government programs, including in the healthcare space, and trade and customs fraud (for more detailed analysis related to the Administration's potential complementary use of civil false claims tariff enforcement, see our prior client alert here).¹ It also includes crimes with a nexus to the Department's broader efforts to prosecute conduct that "enables" cartels or other Transnational Criminal Organizations ("TCOs") (for more detailed analysis related to the Administration's designation of cartels and TCOs, see our prior client alert here).² Consistent with the Administration's foreign policy goals, there is particular emphasis on investigating and prosecuting criminal conduct affiliated with "hostile nation-states" and "terror regimes."

Citing a goal of avoiding lengthy and overbroad investigations, the Enforcement Plan says the Department's new white collar enforcement regime will be guided by three core tenets, discussed in detail below: focus, fairness and efficiency. The Enforcement Plan instructs prosecutors to "prioritize schemes involving senior-level personnel or other culpable actors, demonstrable loss and efforts to obstruct justice."

A. Areas of Focus

The Enforcement Plan lists ten "high-impact areas" where the Criminal Division will focus its resources. The list includes long-standing areas of focus for the Department, while also clearly emphasizing the Administration's publicly-stated law enforcement priorities (e.g., government efficiency, narcotics and enforcement against China). Specifically, the ten "high-impact areas" enumerated are:

Waste, fraud and abuse that "harm" the public fisc;
Trade and customs fraud, including tariff evasion;
Market manipulation or other fraud, especially if perpetrated by or through Chinese-affiliated companies listed on U.S. exchanges ("variable interest entities" or "VIEs");
Investment fraud;
Sanctions violations;
Money laundering offenses;
Material support by corporations to foreign terrorist organizations;
Unlawful manufacturing or distribution of narcotics and opioids;
Bribery that impacts U.S. national interests, undermines U.S. national security, harms the competitiveness of U.S. businesses, or enriches foreign corrupt officials; and
Crimes involving digital assets, including investor or consumer fraud and the use of digital assets in furtherance of criminal activity.

While long-standing Department priorities are included on this list (e.g., Medicaid/Medicare fraud and market manipulation), the list also highlights areas of focus for criminal enforcement aligned with the Administration's "America First" priorities. These areas include trade and customs fraud, tariff evasion, fraud committed by Chinese-affiliated entities and material support to the international cartels that were recently designated as Foreign Terrorist Organizations ("FTOs") or other TCOs.³

The Criminal Division Enforcement Plan also highlights certain priority areas of focus that have historically been spearheaded by the National Security Division, including, for example, material support to foreign terrorist organizations and sanctions violations. This is, in part, a result of the designation of certain international cartels as foreign terrorist organizations, which has complicated the historical ownership of issue sets between the Criminal Division and National Security Division. It remains to be seen how these matters will be handled in practice across the Department.

In light of the President's Executive Order issued on February 10, 2025, which temporarily paused Foreign Corrupt Practices Act enforcement,⁴ it is notable that the Enforcement Plan's list of priorities includes "bribery and associated money laundering that impact U.S. national interests, undermine U.S. national security, harm the competitiveness of U.S. businesses and enrich foreign corrupt officials." The inclusion of bribery on this list affirms the Department's commitment to investigating and prosecuting bribery, including foreign bribery, in cases that it deems in the U.S. national interest.

B. Fairness

The Enforcement Plan next addresses the concept of "fairness" in prosecuting corporations and individuals and announces revisions to the Criminal Division's Corporate Enforcement and Voluntary Self-Disclosure Policy ("CEP"). The Plan notes that this policy, designed to prosecute white-collar offenders, was developed because "justice demands the equal and fair application of criminal laws to individuals and corporations who commit crimes," and in the case of white collar crime, "it is individuals—whether executives, officers, or employees of companies—who commit these crimes, often at the expense of shareholders, workers, and American investors and consumers." Yet in the next breath, the Plan acknowledges that "not all corporate misconduct warrants federal criminal prosecution" and that "it is critical to American prosperity to promote policies that acknowledge law-abiding companies and companies that are willing to learn from their mistakes."

These balancing priorities and the Division's stated overall commitment to transparency necessitate that the Criminal Division "consider additional factors when determining whether to charge corporations." These factors include (1) whether the company reported the conduct to the Department, (2) its willingness to cooperate with the government and (3) its actions to remediate the misconduct.

The Enforcement Plan suggests that the Department may be more open to non-criminal resolutions of corporate misconduct. In particular, the Enforcement Plan notes that "civil and administrative remedies directed at corporations[] are often appropriate to address low-level corporate misconduct." It also instructs prosecutors to consider "all forms" including "non-prosecution agreements, deferred prosecution agreements, and guilty pleas," suggesting a potential shift away from the emphasis on guilty pleas that we saw in the Biden Administration. To achieve these goals, the Enforcement Plan announces revisions to the CEP such that its "core components" are "more easily understandable." These revisions are addressed in more detail below in Section III.A.

Additionally, the Criminal Division has stated that it will conduct a review of all existing agreements with companies to determine if early termination is appropriate for any existing resolutions. This statement follows the April 2025 early termination of Albemarle Corporation's 2023 non-prosecution agreement ("NPA"), a resolution reached with the DOJ after Albemarle's self-reporting Foreign Corrupt Practices Act ("FCPA") violations in 2018.

C. Efficiency

Consistent with the Administration's focus on efficient use of government resources, the Enforcement Plan lays out procedural reforms intended to reduce the cost and duration of white collar investigations. The reforms indicate that moving forward, the Department will be more reluctant to impose compliance monitors, and prosecutors will be encouraged to more quickly reach charging decisions and resolve outstanding cases.

The Enforcement Plan indicates that compliance monitors will be used more sparingly, and when monitorships are imposed, they are likely to have more limited mandates than in the past. Specifically, the Enforcement Plan says that independent compliance monitors will only be imposed when necessary, and that monitorships will be "narrowly tailored to achieve the necessary goals while minimizing expense, burden, and interference with the business." The Enforcement Plan also lays out a new monitor selection memorandum (discussed in Section III.B). A review of all existing monitorships by the Department is ongoing; the review has been described as an assessment of whether some monitorships should be terminated or curtailed.

The Enforcement Plan also states it will be the Department's goal to minimize the length and cost of investigations. Accordingly, the Enforcement Plan instructs prosecutors to take "all reasonable steps to minimize the length and collateral impact of their investigations, and to ensure that bad actors are brought to justice swiftly and resources are marshaled efficiently." Accordingly, prosecutors are instructed to "move expeditiously to investigate cases and make charging decisions."

III. Policy Revisions

As previewed in the Enforcement Plan, the DOJ issued three revised policies on May 12, 2025. Some of the updates are more notable than others, but all are in line with the stated priorities of the Enforcement Plan and the Trump Administration's approach to corporate enforcement more broadly.

A. Revised Corporate Enforcement and Voluntary Self-Disclosure

In May 12, 2025 remarks to the Securities Industry and Financial Markets Association's ("SIFMA") AML and Financial Crimes Conference, Mr. Galeotti characterized the prior versions of the CEP as "unwieldy and hard to navigate" and explained that, in contrast, the revised policy seeks to be "as transparent as [it] can to companies and their counsel about what to expect."⁵ As Mr. Galeotti previewed, the DOJ's revised Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy ("May 2025 CEP")—the shortest and most streamlined version of CEP ever—will likely result in more declinations and broader applicability of the CEP in practice.

Like past iterations of the CEP, the May 2025 CEP is focused on transparently describing incentives for corporate self-disclosure. Perhaps the most notable change is the shift from a presumption of a declination to a more definitive statement that, upon meeting the established criteria, a company "will" receive a declination. The revised policy also introduces the concept of "near miss" voluntary self-disclosures and specifically prescribes that a company should receive an NPA both in situations where the company acted in good faith by self-reporting but its disclosure did not qualify as a voluntary self-disclosure and in certain matters involving aggravating circumstances. The core requirements for a declination under the May 2025 CEP have not changed: a company must voluntarily self-disclose misconduct to the Criminal Division, fully cooperate, timely and appropriately remediate the misconduct and not have the existence of aggravating circumstances.

The revised CEP notably removes the onerous requirements that formerly needed to be met for a company to receive a CEP declination in situations where aggravating circumstances are present and instead gives prosecutors full discretion to recommend a CEP declination in the presence of aggravating circumstances "based on weighing the severity of those circumstances and the company's cooperation and remediation."

The new "near miss" category established by the May 2025 CEP provides that if a company fully cooperated and timely and appropriately remediated, but the company is ineligible for a declination due to (1) the fact that a self-disclosure made in good faith does not meet the definition of a voluntary self-disclosure or (2) the presence of aggravating factors warranting a criminal resolution, the Criminal Division "shall" nonetheless: enter into an NPA (absent particularly egregious aggravating circumstances); allow a term length of fewer than three years; not require an independent compliance monitor; and provide a 75% reduction off the low end of the sentencing guidelines. Incentives for this new "near miss" category are greater than those that were previously afforded to companies that voluntarily self-disclosed, fully cooperated and timely and appropriately remediated but for which criminal resolutions were nevertheless warranted. For example, the guidelines reduction was at least 50% and up to 75% (and not generally from the low end of the range), and while the Department was clear that a guilty plea would generally not be required, both DPAs and NPAs were potential outcomes. Similarly, while the prior CEP gave "limited credit" for companies that fully cooperated and timely and appropriately remediated but did not voluntary disclose, that credit was limited to 50% off the low end of the guidelines range (unless the company was a recidivist, in which case the 50% reduction would not be from the low end).

These revisions notably preserve a significant substantive amendment to the CEP last year, effective August 1, 2024, related to the Corporate Whistleblower Awards Pilot Program. The amendment provided that companies that receive an internal report of misconduct from a whistleblower who also makes a whistleblower submission to the DOJ are able to obtain the full benefits of the CEP, as long as the company self-reports to the DOJ within 120 days after receiving the whistleblower allegation, and the disclosure takes place before the DOJ reaches out to the company.⁶

The May 2025 CEP also includes a flow chart of possible outcomes for a company seeking to make a voluntary self-disclosure, likely seeking to ensure the "maximum transparency" promised by Mr. Galeotti.

B. Memorandum on Selection of Monitors in Criminal Division Matters

The DOJ also issued another iteration of policy guidance on the imposition and selection of monitors in criminal division matters. The Memorandum on Selection of Monitors in Criminal Division Matters ("2025 Monitor Memo")⁷ follows the March 2025 termination of Glencore's MIMF and FCPA monitorships and a subsequent "pause" and review of all active Criminal Division monitorships. The May 2025 Monitor Memo explicitly incorporates prior guidance from the 2008 Morford Memorandum on the selection and use of monitors and "revises and supersedes" Criminal Division memoranda on the same topic from 2009, 2018 and 2023. The 2025 Monitor Memo makes significant narrowing changes to the circumstances in which monitors should be imposed and establishes greater oversight by the Department of monitors that are imposed going forward, including, for the first time, detailed guidance on how the Department should assess and oversee budgets and costs associated with monitorships.

Imposition of Monitors

The 2025 Monitor Memo reaffirms that monitors "can be an effective resource" in ensuring that corporate offenders comply with the terms of their resolutions, including the implementation of an effective compliance program, but is also quick to note that monitors can also impose substantial expense and distraction. Accordingly, after reiterating past guidance that the imposition of a monitor should never be punitive, the 2025 Monitor Memo states that the scope of any monitorship must be appropriately tailored to "address specific issues and concerns that created the need for the monitor while minimizing expense, burden, and interference with the business."⁸

Like past guidance on the imposition of monitorships, the 2025 Monitor Memo makes clear that the imposition of a monitor will be a case-specific determination. Also, like past guidance, the 2025 Monitor Memo lays out factors for prosecutors to consider in evaluating the necessity and potential benefits of a monitor. While not a specifically enumerated factor in the 2025 Monitor Memo, the memo directs prosecutors to assess "the incremental benefits the monitor has above and beyond" other requirements imposed on corporate leadership in all Criminal Division resolutions—e.g., the obligation of corporate leadership to, at the conclusion of the resolution, certify an effective compliance program. Taken together with the enumerated and narrowed criteria for when imposition of a monitor may be appropriate, the 2025 Monitor Memo can fairly be read to suggest that the imposition of monitors may be disfavored by this Administration, or at the very least will be imposed only in rare circumstances.

Notable changes to and narrowing of the factors relevant to the imposition of a monitor include the following:

While the risk of recurrence of criminal conduct has always been a factor in assessing the need for a monitor, the 2025 Monitor Memo ties the potential for recurrence specifically to U.S. interests—g., offenses detrimental to national security, foreign bribery that significantly impacts U.S. interests and crimes that facilitate cartels and TCOs and narcotics trafficking. Limiting the imposition of a monitorship to instances where the risk of recurrence impacts U.S. interests mirrors stated enforcement priorities from AG Bondi's February 5, 2025 memorandum establishing DOJ enforcement priorities.
The 2025 Monitor Memo also establishes regulation by other U.S. or international regulatory bodies as a factor to consider, noting that if a Company's primary regulator can exercise sufficient oversight to ensure the imposition of an effective compliance program in connection with the company's self-directed efforts, there is no need for a monitor. Conversely, the 2025 Monitor Memo is explicit that a history of misconduct on the watch of an entity's primary regulator "might counsel" in favor of a monitor. While past monitor guidance also established the extent of regulation as a factor to consider, the 2025 Monitor Memo appears to assign greater weight to this factor and signal that DOJ monitorships may be disfavored for highly regulated entities.
The 2025 Monitor Memo, like past guidance, establishes any pre-resolution remediation as an important factor but, for the first time, provides that a company's voluntary engagement of "third-party consultants, auditors, and other experts" could obviate the need for a DOJ appointed monitor, continuing the theme of corporate independence and self-directed compliance efforts running through the most recent guidance.

Like past guidance, the 2025 Monitor Memo explains that changes to a company's risk profile and whether the company has tested enhancements to ensure they are working effectively as additional factors to consider in assessing whether a monitor is appropriate. With these changes to the factors regarding the imposition of monitorships, the Department is clear that it is going to take a hard look at whether and why a monitor is necessary. As noted above, while monitorships are not dead, it is likely we will see fewer monitors imposed and more leeway afforded companies to independently drive enhancements to their programs during this Administration.

Ensuring Monitorships are Appropriately Tailored and Focused

The most notable changes established by the 2025 Monitor Memo are with respect to the Department's oversight of monitorships. While the Department has always pledged to oversee monitors it imposes pursuant to its resolutions with corporate defendants and ensure that the monitors' work is appropriately scoped, for the first time, the 2025 Monitor Memo establishes concrete steps to achieve this oversight. Specifically:

The 2025 Monitor Memo provides that a monitor's costs must be proportionate to: (1) the severity of the underlying conduct, including as reflected by the fine and any forfeiture imposed, (2) the profits of the relevant corporate entity and, if appropriate, the larger organization and (3) the company's present size and risk profile.
The 2025 Monitor Memo states that the Department will "require a cap on hourly rates charged" by monitors and requires, shortly after selection, a budget for completing the entire monitorship. Additionally, monitors must provide an updated estimate of costs at the start of each period of monitor review. The 2025 Monitor Memo is clear that the estimates must be approved by the Criminal Division and that the monitor will not be paid more than the approved amount absent prior written approval from the Criminal Division upon a showing that additional work is necessary to achieve the terms of the agreement.
Establishing the Department as a key player in the "collaborative endeavor" of a monitorship, the 2025 Monitor Memo requires criminal resolutions to mandate "at least bi-annual tri-partite meetings" between the company, the monitor and the government and describes these tri-partite meetings as an important tool to mitigate monitor overreach. While these tri-partite meetings have long been a requirement in the DOJ template attachment defining the mandate of the monitor, this is the first time the importance of these meetings has been highlighted in a monitorship policy memo.
Relatedly, the 2025 Monitor Memo calls for "an ongoing and open dialogue between the Criminal Division, the Company, and the Monitor about the progress of the monitorship." The 2025 Monitor Memo is explicit that corporate efforts to ensure appropriate scope of the monitorship and to push back against proposed actions that may be unnecessary or overly burdensome should not necessarily be viewed by the monitor as a failure by the company to take seriously compliance and remediation. Conversely, the company should not by default treat "appropriate requests and recommendations" from the monitor as unnecessary intrusion.

Finally, like prior iterations of monitor guidance, the 2025 Monitor Memo outlines the selection and approval process utilized by the Department prior to imposing a monitor. The 2025 Monitor Memo maintains much of the selection process from earlier guidance—the preparation of a Monitor Recommendation Memorandum, the initial review by a Standing Committee, concurrence or disagreement with the recommendation of the Standing Committee by the Assistant Attorney General and ultimate approval remains the purview of the Office of the Deputy Attorney General. The May 2025 Monitor Memo preserves a company's ability to identify their first choice of the submitted candidates. Unsurprisingly given the Trump Administration's actions to abolish diversity, equity and inclusion programs, the May 2025 Monitor Memo removes the statement that selection of monitors should be made in keeping with the Department's commitment to diversity and inclusion and replaces it with the statement that selection of the monitor candidate should be made without unlawful discrimination against any person or class of persons.

With its changes to the criteria to be evaluated when considering the imposition of a monitor and the specific guardrails imposed by the Department when a monitor is required as a condition of resolution, the 2025 Monitor Memo provides welcome guidance on the Trump DOJ's approach to monitorships. Overall, the 2025 Monitor Memo suggests a narrowed approach to the imposition of monitors than past administrations—even compared to the first Trump Administration, which gave rise to the 2018 Benczkowski memorandum on the Selection of Monitors in Criminal Division Matters⁹—and positions the imposition of monitors as something that must further the overall enforcement goals of the current Administration.

C. Criminal Division's Corporate Whistleblower Awards Pilot Program Revised

On May 12, 2025, the DOJ Criminal Division revised the Corporate Whistleblower Awards Pilot Program. The Pilot Program sets forth the criteria that individuals must meet in order to qualify for the payment of an award in the Department's discretion.¹⁰ Pursuant to the program, whistleblowers may be eligible for a monetary award when they provide original, truthful information about criminal misconduct relating to one or more designated program areas that leads to forfeiture exceeding $1,000,000 in net proceeds and the whistleblowers meet the other requirements of the program. The revisions to the Pilot Program expand the qualifying program areas to also include: "fraud against, or the deception of, the United States in connection with federally funded contracting or federal programs"; "trade, tariff, and customs fraud"; "federal immigration law"; and "sanctions offenses, material support of terrorism, or cartels and transnational criminal organizations including money laundering, narcotics, Controlled Substances Act, and other violations."¹¹ The revised Pilot Program also expands the scope of health care fraud that will qualify. The previous version of the program limited this topic to private health care benefit programs.¹² The revised version now encompasses health care offenses and related crimes involving both private and public health care benefit programs. These additional program areas now covered by the Pilot Program closely align with the Trump Administration's stated priorities.¹³

IV. Key Takeaways for Companies

With the announcement of the white collar enforcement plan, and the related policy revisions and monitor memo release, the new leadership of the Department's Criminal Division have further outlined their priorities and objectives. It is unsurprising that many of these priorities closely align with the Administration's already articulated "America First" priorities, including prioritizing criminality related to waste, fraud and abuse, national security, sanctions, trade policy and cartels. Other key takeaways are:

Bribery: It is notable that bribery was included on the list of white collar priorities. The inclusion of bribery appears to affirm the Department's commitment to investigate and prosecute bribery, including foreign bribery, in cases that it deems in the U.S. national interest.
Continued Focus on Corporate Voluntary Self-Disclosures: The updates to the Corporate Enforcement Policy show that the Department will continue to seek to incentivize corporate voluntary self-disclosures. Among the most notable changes to the policy is the additional discretion given to prosecutors in cases involving aggravating circumstances and the corresponding removal of the formerly onerous requirements for obtaining a CEP declination in matters involving aggravating circumstances.
Continuation and Expansion of the Corporate Whistleblower Awards Pilot Program: The updates to the Corporate Whistleblower Awards Pilot Program show that the administration will continue to seek leads for cases by providing the possibility for monetary reward to whistleblowers. The revisions do not materially alter the existing program, and instead build and expand on the program by adding qualifying areas, such as fraud against the United States in connection with health care benefit programs, contracting, or other federal programs, immigration law, and offenses with a national security nexus, such as sanctions violations, material support to foreign terrorist organizations and assistance to transnational criminal organizations like cartels, each of which closely aligns with the Administrations enforcement priorities.
Narrowly Tailoring Monitorships: The Memorandum on Selection of Monitors in Criminal Division Matters makes significant narrowing changes to the circumstances in which monitors should be imposed and establishes greater oversight by the Department of monitors that are imposed going forward, including, for the first time, detailed guidance on how the Department should assess and oversee budgets and costs associated with monitorships.
Directive for Investigative Efficiency: It will be interesting to see whether the Enforcement Memo's directive that prosecutors move expeditiously to investigate cases and make charging decisions and the announcement that the office of the Head of the Criminal Division will be closely tracking investigations to ensure that they do not linger and are swiftly concluded results in shorter investigations and faster decisions in cases going forward.

Footnotes

1. See Matt Jones, Neena Shenai, Carrie Montgomery, Stephanie Hartmann, Patrick Selwood, Heather Hedges, As Tariffs Increase, So Too May the Use of False Claims Actions to Pursue Customs Fraud (Mar. 10, 2025), https://www.wilmerhale.com/en/insights/client-alerts/20250310-as-tariffs-increase-so-too-may-the-use-of-false-claims-actions-to-pursue-customs-fraud.

2. See David Bowker, Joshua Geltzer, Zachary Goldman, Ari Holtzblatt, David Ogden, Aaron Zebley, Alyson Zureick, Donna Farag, Mark Hanin, Sonika Data, Sara Maldonado, Implications of EO 14157 and Recent "Foreign Terrorist Organization" and "Specially Designated Global Terrorist" Designations (Apr. 22, 2025), https://www.wilmerhale.com/en/insights/client-alerts/20250422-implications-of-eo-14157-and-recent-foreign-terrorist-organization-and-specially-designated-global-terrorist-designations.

3. 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).

4. See Executive Order 14209, Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security (Feb. 10, 2025) (FCPA Executive Order).

5. Office of Public Affairs, U.S. Department of Justice, Head of the Criminal Division, Matthew R. Galeotti Delivers Remarks at SIFMA's Anti-Money Laundering and Financial Crimes Conference (May 12, 2025), available at https://www.justice.gov/opa/speech/head-criminal-division-matthew-r-galeotti-delivers-remarks-sifmas-anti-money-laundering.

6. See 9-47.120 – Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy (updated May 12, 2025), available at https://www.justice.gov/criminal/media/1400031/dl?inline, at 4 (Appendix B, Voluntary Self-Disclosure – Corporate Whistleblower Awards Pilot Program Exception.)

7. Matthew R. Galeotti, Memorandum on Selection of Monitors in Criminal Division Matters (May 12, 2025), available at https://www.justice.gov/criminal/media/1400036/dl?inline.

8. Id. at 2.

9. Brian A. Benczkowski, Selection of Monitors in Criminal Division Matters (Oct. 11, 2018), available at https://www.justice.gov/d9/speeches/attachments/2018/10/12/selection_of_monitors_in_criminal_division_matters_memo_0.pdf.

10. See U.S. Department of Justice, Department of Justice Corporate Whistleblower Awards Pilot Program, at 5-6 (May 12, 2025).

11. See U.S. Department of Justice, Department of Justice Corporate Whistleblower Awards Pilot Program, at 6 (May 12, 2025).

12. U.S. Department of Justice, Department of Justice Corporate Whistleblower Awards Pilot Program, at 6 (Aug. 1, 2024).

13. See Issues, The White House, https://www.whitehouse.gov/issues/ (last accessed May 13, 2025).

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