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Client Alert: DOJ Reprioritizes Corporate Enforcement with Key Policy Revisions

By Thomas Hanusik, Alexander J. Kramer, Nimrod Aviad, Carlton Greene, Anand Sithian, Jeff Severson, Samuel C. Blackington & Rachel Bogin on May 14, 2025
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In a May 12, 2025 speech that signaled both a recalibration of and recommitment to prosecuting white-collar crime, Matthew R. Galeotti, the newly appointed Head of the Department of Justice’s Criminal Division, said that the Division is “turning a new page” and embracing an enforcement approach that aims to elevate efficiency, predictability, and fairness. The changes he outlined aim to incentivize self-reporting, narrow corporate monitorships, and refocus whistleblowers.

Click here to continue reading the full version of this alert.

Photo of Thomas Hanusik Thomas Hanusik

Tom Hanusik is a partner in Washington D.C. and a member of Crowell & Moring’s White Collar & Regulatory Enforcement Group, which Law360 named a “White Collar Group of the Year” in 2012 and one of ten “FCPA Powerhouses” in 2013. Tom is…

Tom Hanusik is a partner in Washington D.C. and a member of Crowell & Moring’s White Collar & Regulatory Enforcement Group, which Law360 named a “White Collar Group of the Year” in 2012 and one of ten “FCPA Powerhouses” in 2013. Tom is also chair of Crowell & Moring’s Investigations practice and a member of the firm’s Management Board.

Tom’s practice focuses on white collar defense, SEC Enforcement, FINRA Enforcement and internal investigations. He defends publicly traded and privately held companies, senior executives, board members and politicians during internal and government investigations, criminal and civil trials, regulatory enforcement actions, and appeals. Tom has over twenty years of trial and appellate experience. He also leads teams conducting internal investigations on behalf of companies, boards of directors and board committees, as well as advising corporate clients on remedial measures, compliance programs and training. Tom’s recent engagements include representing institutions and executives in matters involving alleged violations of federal securities laws including financial fraud, insider trading, FCPA and Section 5 violations, AML requirements, federal and state tax offenses, public corruption and violations of U.S. export controls and sanctions regulations.

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Photo of Alexander J. Kramer Alexander J. Kramer

Alexander J. Kramer is a partner in the White Collar and Regulatory Enforcement Group, bringing a wealth of experience from his distinguished career at the United States Department of Justice (DOJ). Alex has extensive experience in white collar crime and investigations, including the…

Alexander J. Kramer is a partner in the White Collar and Regulatory Enforcement Group, bringing a wealth of experience from his distinguished career at the United States Department of Justice (DOJ). Alex has extensive experience in white collar crime and investigations, including the Foreign Corrupt Practices Act (FCPA) and anti-corruption issues, health care fraud, significant fraud by government contractors, public companies, financial institutions, and other entities dealing with the DOJ, the U.S. Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), and related parallel enforcement actions.

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Photo of Nimrod Aviad Nimrod Aviad

Nimrod (Nimi) Aviad is a partner in Crowell & Moring’s Los Angeles office, where he is a member of the White Collar Crime and Regulatory Enforcement Group and of the firm’s Investigations Group.

Nimi’s practice focuses on representing and counseling corporate and individual…

Nimrod (Nimi) Aviad is a partner in Crowell & Moring’s Los Angeles office, where he is a member of the White Collar Crime and Regulatory Enforcement Group and of the firm’s Investigations Group.

Nimi’s practice focuses on representing and counseling corporate and individual clients in white collar criminal defense, regulatory enforcement actions, grand jury investigations, internal corporate investigations, and in related complex civil litigation matters.

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Photo of Carlton Greene Carlton Greene

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering…

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Carlton is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act.

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Photo of Anand Sithian Anand Sithian

For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand

…

For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand is resident in the firm’s New York office and a member of the firm’s International Trade, White Collar and Regulatory Enforcement, and Financial Services groups.

A former federal prosecutor, Anand leverages his government experience to guide clients through complex white-collar matters, including grand jury and regulatory investigations, enforcement proceedings, and internal investigations. Anand has deep experience in parallel criminal and civil investigations and proceedings, and often represents clients in defending against civil lawsuits related to government investigations.

Representing some of the world’s largest banks and technology companies, Anand has addressed a wide range of issues, including economic sanctions, BSA/AML; economic sanctions and national security; payments and cryptocurrency; securities laws; and cybersecurity enforcement. In the regulatory space, Anand prides himself on providing commercial and actionable advice, including in the developing areas of digital assets, FinTech, and payments.

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Photo of Jeff Severson Jeff Severson

Jeffrey M. Severson represents individual and corporate clients facing complex, high-stakes criminal and regulatory investigations initiated by the full slate of federal and state regulators. Jeff uses his experience navigating the complex demands of regulatory investigations and criminal prosecutions to fashion effective defense

…

Jeffrey M. Severson represents individual and corporate clients facing complex, high-stakes criminal and regulatory investigations initiated by the full slate of federal and state regulators. Jeff uses his experience navigating the complex demands of regulatory investigations and criminal prosecutions to fashion effective defense strategies and collaborate with his clients to guide them to successful outcomes.

Jeff has advised clients in investigations launched by the Department of Justice, Securities and Exchange Commission, Commodity Futures Trading Commission, Financial Industry Regulatory Authority, Federal Reserve Board, and offices of state attorneys general, as well as internal investigations that involve potential criminal or regulatory exposure. In particular, he has experience defending allegations related to the Foreign Corrupt Practices Act; securities fraud; health care fraud; environmental, social, and governance–related disclosures; and criminal antitrust violations. Jeff has advised clients across a wide range of industries, including health care, technology, financial services, and defense.

Jeff also maintains an active pro bono practice and focuses on representing clients in asylum and refugee resettlement proceedings, as well as indigent criminal defendants in the Southern District of New York as part of the Criminal Justice Act panel, in cases ranging from narcotics trafficking to securities fraud. For his service, Jeff was awarded Crowell & Moring’s George Bailey Pro Bono Award in 2017.

While at Fordham Law School, Jeff was the senior articles editor for the Fordham International Law Journal, a Stein Scholar for the Public Interest, and a Crowley Scholar in International Human Rights. Prior to law school, he worked for a prominent international human rights organization.

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Photo of Samuel C. Blackington Samuel C. Blackington

Sam Blackington is an associate in Crowell & Moring’s New York office. He is a member of the White Collar and Regulatory Enforcement Group. Before joining Crowell, Sam clerked for the Honorable Nancy D. Freudenthal in the U.S. District Court for the District

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Sam Blackington is an associate in Crowell & Moring’s New York office. He is a member of the White Collar and Regulatory Enforcement Group. Before joining Crowell, Sam clerked for the Honorable Nancy D. Freudenthal in the U.S. District Court for the District of Wyoming. During this term, he also assisted the Honorable Kelly H. Rankin and the Honorable Alan B. Johnson.

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Photo of Rachel Bogin Rachel Bogin

Rachel Bogin is an associate in the International Trade and White Collar and Regulatory Enforcement practices in Crowell & Moring’s Washington, D.C. office. Rachel is experienced in analyzing global sanctions and export control regimes to provide compliance guidance, examining domestic import regulations, and…

Rachel Bogin is an associate in the International Trade and White Collar and Regulatory Enforcement practices in Crowell & Moring’s Washington, D.C. office. Rachel is experienced in analyzing global sanctions and export control regimes to provide compliance guidance, examining domestic import regulations, and providing client representation in government investigations.

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  • Posted in:
    International
  • Blog:
    International Trade Law
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

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