Baker McKenzie has recently published a client alert regarding the US Department of Justice’s New Fraud Division Corporate Enforcement Directive issued on October 1, 2026. Corporate fraud schemes involving tariff evasion, importation of goods or services, or forced labor, are one of the four priority areas the Directive sets for Fraud Division prosecutors. The alert discusses the Division’s new Corporate Enforcement Section, the factors prosecutors must weigh heavily in corporate cases, and the Division’s use…
On March 30, 2026, the US Department of Justice (“DOJ”) National Security Division (“NSD”) announced updated guidance clarifying how companies should report voluntary self-disclosures (“VSDs”) of potential criminal violations of US national security laws, including export controls and sanctions, under DOJ’s new department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (“CEP”). The announcement reflects NSD’s transition away from its prior division-specific VSD policy in favor of the department-wide CEP released on March 10, 2026 (covered in…
Emphasis on protecting US business, economic and national security interests In brief During a May 12 speech and in a newly issued Criminal Division White-Collar Enforcement Plan (the “Plan”), the Head of the US Department of Justice (DOJ)’s Criminal Division, Matthew R. Galeotti, set out the Department’s priorities for corporate criminal enforcement under the new Administration and issued a number of updated policy documents. These changes affect the Criminal Division’s Corporate Enforcement and Voluntary Self-Disclosure…
On February 20, 2025, the US Department of State designated several international cartels and transnational criminal organizations as Foreign Terrorist Organizations (“FTOs”) pursuant to section 219 of the Immigration and Nationality Act and as Specially Designated Global Terrorists (“SDGTs”) pursuant to Executive Order (“EO”) 13224. These parties have been designated for “threaten[ing] the safety of the American people, the security of the United States, and the stability of the international order in the Western Hemisphere,”…