The DOJ’s New Enforcement Playbook: 10 White-Collar Priorities and How Ethical Leaders Can Stay Ahead

By Chuck Gallagher – Business Ethics Keynote Speaker | AI Speaker and Author

It Started with a Shift. Now It’s a Spotlight.

In May 2025, the U.S. Department of Justice didn’t just pivot—it planted a flag.

With a new initiative titled “Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime,” DOJ prosecutors announced ten strategic enforcement priorities. These weren’t mere suggestions; they were an unmistakable roadmap to who—and what—would face increased scrutiny going forward.

Now, if you’re a business leader, compliance officer, or C-suite executive, you’re no longer asking “Will we be targeted?” but rather “Are we vulnerable?”

The 10 High-Impact Focus Areas

Here’s what DOJ enforcement teams will focus on:

1. Healthcare Fraud – COVID-19 relief schemes, billing fraud, and exploitation of public health funding.

2. Procurement and Federal Program Fraud – False claims and bid-rigging tied to taxpayer dollars.

3. Trade and Customs Fraud – Tariff evasion, mislabeling, and smuggling.

4. Securities and Commodities Fraud – Insider trading, Ponzi schemes, misleading investors.

5. Market Manipulation and VIE Fraud – Foreign entity misuse, shell companies, deceptive listings.

6. Elder Fraud and Consumer Exploitation – Scams targeting seniors or violating consumer protection statutes.

7. Complex Money Laundering – Especially with ties to Chinese Money Laundering Organizations and crypto assets.

8. Controlled Substances and FDA Violations – Fentanyl distribution and illegal prescription activity.

9. Support to Cartels, TCOs, or Terrorist Groups – Material or financial aid to criminal organizations.

10. Sanctions Violations – Transactions with banned countries or designated individuals/entities.

These ten areas are united by one theme: impact. The DOJ is targeting fraud that shakes public trust, disrupts economic systems, and exploits the vulnerable.

So What Can You Do? Five Strategic Mitigation Imperatives

The DOJ isn’t just chasing criminals—it’s raising the bar on what ethical leadership and corporate responsibility must look like. Here’s how to stay ahead of the curve.

1. Map Your Risk Landscape to the DOJ’s Ten Areas

Most organizations already run basic risk assessments. Now, it’s time to upgrade that approach:

• Identify direct and indirect exposure to the DOJ’s ten areas.

• Use heat maps, AI tools, and forensic accounting to detect anomalies early.

• Break down exposure by department—sales, finance, HR, procurement, supply chain, and tech.

Example: If you import parts internationally, analyze your trade compliance and harmonized tariff code classifications for exposure to customs fraud.

2. Create a DOJ-Focused Internal Audit Protocol

Not all audits are created equal. The DOJ has made it clear that companies with proactive compliance and audit programs will receive leniency, even if misconduct is discovered.

Build a targeted internal audit process with:

• Specific focus on high-risk DOJ categories

• Integration of AI tools that flag unusual patterns (e.g., sudden payroll increases or vendor anomalies)

• Board-level reporting to ensure visibility and accountability

Bonus Tip: Simulate a DOJ investigation quarterly—just like fire drills—so your team knows what scrutiny feels like before it happens.

3. Reevaluate Vendor and Partner Due Diligence

One of the biggest blind spots in white-collar exposure? Third parties.

If your vendors are laundering money, violating sanctions, or evading customs duties—you may be liable. The DOJ’s recent focus on complex money laundering and trade fraud makes this critical.

Ensure:

• Enhanced vetting of international and shell entities

• Use of tools to track Ultimate Beneficial Owners (UBOs)

• Real-time monitoring of politically exposed persons (PEPs) and sanctioned parties

4. Formalize a Voluntary Self-Disclosure Path

The DOJ has emphasized it will reward companies that report early, remediate swiftly, and cooperate fully.

That means you need:

• A clear, documented pathway for whistleblowers, internal findings, and legal consultation

• Pre-drafted response protocols, including timelines and communication strategies

• Legal review pipelines to determine materiality and disclosure thresholds

Ethical companies don’t fear discovery—they prepare for transparency.

5. Elevate Ethics as a Leadership Function

Too many companies bury ethics in compliance or HR. That won’t cut it anymore.

As a business ethics keynote speaker and former executive, I can tell you this: what leaders tolerate becomes culture. You need executives visibly championing:

• Ethics-first decisions (especially in revenue-generating functions)

• Speaking engagements, team town halls, and boardroom discussions that center on values

• Incentive systems that reward transparency—not just results

Call to Action

The DOJ isn’t just increasing scrutiny—it’s clarifying expectations. What was once considered “compliant” may no longer be enough. The real question is:

Are you ready to lead with ethics when the pressure’s highest—and the spotlight is brightest?

Drop your thoughts below. Let’s raise the bar, together.