United States: White Collar Crime, Anti-Corruption & Fraud

When a congressional inquiry surfaces facts that attract DOJ attention, or an enforcement action triggers legislative scrutiny, companies face a complex challenge: managing investigations across multiple forums where document productions, witness statements, and strategic decisions in one proceeding can reshape risk in another. Understanding how these investigations intersect—and preparing before the second letter arrives—has become essential as the 2026 midterm elections promise to shift oversi

The Department of Justice has dramatically expanded customs enforcement beyond traditional CBP penalties, now pursuing foreign companies and individual executives through False Claims Act litigation and criminal charges. Recent cases reveal four critical patterns that expose companies to civil treble damages, criminal prosecution, and personal liability for executives—even when violations began years before current trade tensions escalated.

The Department of Justice's National Fraud Enforcement Division and HHS Office of Inspector General have announced a coordinated policy that streamlines voluntary self-disclosures of healthcare fraud. Companies can now disclose potential criminal conduct to a single point of contact and receive benefits under both DOJ's Corporate Enforcement Policy and HHS-OIG's Self-Disclosure Protocol, eliminating the need for multiple simultaneous disclosures.

The U.S. Treasury's Financial Crimes Enforcement Network has uncovered $17.5 billion in suspicious financial activity tied to health care fraud schemes, revealing how fraudulent providers exploit Medicare, Medicaid, and private insurance programs. Analysis of over 5,700 Bank Secrecy Act reports exposes sophisticated money laundering networks spanning all 50 states, with home health care businesses emerging as the most frequently identified perpetrators.

As AI agents begin to shop, select, pay, and move digital assets on behalf of principals, payment disputes will increasingly turn on what the principal authorized the agent to do.

Manhattan District Attorney Alvin Bragg has launched the office's first Corporate Crime and Antitrust Task Force, marking a significant shift toward state-level criminal antitrust enforcement in New York. This development raises questions about coordination with the Attorney General's Office and creates new enforcement risks for businesses operating in the state. The initiative comes amid heightened scrutiny of algorithmic pricing and other corporate practices, though recent court decisions have complicated

The Department of Justice's National Fraud Enforcement Division has unveiled new corporate fraud enforcement priorities targeting health care, government contracts, tax evasion, and trade fraud, while implementing an aggressive, centralized approach to investigations.

A Texas appellate court upheld terrorism charges against a woman whose only alleged contribution was sewing a Faraday bag used to block cell phone signals. This case illustrates how federal and state material support statutes can impose life sentences for seemingly trivial assistance, with no requirement to prove intent to further terrorist activity or any de minimis exception for minor contributions.

The Trump administration is deploying US military forces directly into Latin American counternarcotics operations, marking a significant shift from historical intelligence-sharing roles to boots-on-the-ground combat involvement. Recent joint operations in Ecuador, featuring 50 US troops working alongside local forces to dismantle cartel networks, are establishing a new model that Washington seeks to replicate across the Western Hemisphere.