DOJ Incentivizes Corporate Reporting, Whistleblowing for Sanctions, Tariffs, Immigration Violations

May 16, 2025 - 00:51

Updated: 1 year ago

DOJ Incentivizes Corporate Reporting, Whistleblowing for Sanctions, Tariffs, Immigration Violations

Matthew Galeotti, head of the Justice Department’s Criminal Division, announced a new white-collar crimes enforcement plan at a May 12 financial conference, spotlighting the Trump administration’s focus on disrupting transnational networks that evade U.S. sanctions, tariffs, and immigration law.

It also expanded its whistleblower program to cover these priority areas.

The DOJ will be pulling back on monitoring American corporations, while incentivizing companies to self-report and cooperate with investigations against bad actors.

“Self-disclosure is key to receiving the most generous benefits the Criminal Division can offer. Why? Because coming forward and coming clean lets the Department devote its resources to investigating and prosecuting individual wrongdoers and the most egregious criminal schemes,” Galeotti said, according to prepared remarks.

The DOJ had amended its disclosure policy to incentivize reporting in 2023, highlighting a general policy of deferred or non-prosecution agreements for cooperating companies. The latest version will also limit investigation terms to three years, reduce fines for cooperating companies, and will not require companies that meet requirements to enter into a criminal resolution.

Galeotti said the DOJ is prioritizing tips and whistleblower reports for fraud in government programs like Medicare or procurement; violations of sanctions, especially in ways that support terrorist organizations; and trade violations such as tariff and customs fraud.

White collar crimes have been tied to the material support of foreign hostile nations and terrorist organizations, Galeotti said, especially in money laundering. In a memo published the same day, he singled out Chinese money laundering organizations that exploit the American financial system by way of variable interest entities listed on U.S. exchanges that defraud investors and which facilitate the flow of illicit fentanyl.

“Illicit financial and logistical networks undermine our national security by facilitating sanctions evasion by hostile nation-states and terror regimes,” Galeotti said in his May 12 speech.

In Treasury Department sanctions targeting Iranian regime-backed terrorist groups and the Chinese military, for example, the networks often span the globe.

On May 13, the Treasury Department sanctioned nearly two dozen entities for aiding efforts to build out the Iranian regime’s ballistic missile and terrorist groups, with origins that included Iran, China, the Seychelles, Singapore, Hong Kong, and Panama. They comprised a network that sold sanctioned Iranian oil to China through various intermediaries.

A March 20 round of sanctions targeting another similar network named 19 targets with origins in Iran, China, Hong Kong, Panama, San Marino, Comoros, Barbados, the Seychelles, and the British Virgin Islands.

A February round of sanctions on 30 individuals and vessels included brokers in the United Arab Emirates, Hong Kong, China, and Iran.