Department of Justice Corporate Enforcement: 2025 Year in Review

I. Executive Summary

In 2025, U.S. Department of Justice (“DOJ” or the “Department”) leaders announced significant recalibrations of the Department’s corporate enforcement priorities. For example, in a May 12, 2025 memorandum from then-Acting Assistant Attorney General of DOJ’s Criminal Division, Matthew R. Galeotti, the Criminal Division shifted its focus towards fraudulent conduct that harms the American public and conduct that directly undermines U.S. national security. This shift includes a heightened emphasis on trade and tariff fraud and the prosecution of companies providing “material support” to cartels and Transnational Criminal Organizations (“TCOs”) designated as Foreign Terrorist Organizations (“FTOs”). According to the memorandum, DOJ intends to “protect[] American citizens and companies,” while “minimizing unnecessary burdens on American enterprise.”[i] These types of shifts in priorities are common at the beginning of a new Administration and may preview the types of enforcement actions (and resolutions) coming out of the Department in the next few years.

In conjunction with these new priorities, the Department also issued new guidance on the prosecution of cases involving the Foreign Corrupt Practices Act (“FCPA”) and cases involving digital assets. In both areas, the Department issued memoranda outlining significant changes. Following a temporary enforcement “pause” on FCPA cases early in the year, in June 2025 the DOJ issued new FCPA guidelines identifying priority considerations for future foreign bribery investigations including national security interests, the safeguarding of fair opportunities for U.S. companies and ties to designated cartels and TCOs. With respect to digital assets, in April 2025 the DOJ announced an end to “Regulation by Prosecution” and stated that it would significantly narrow the types of cases it would bring in this area.

Beyond shifting priorities, the Department reaffirmed its intention to reward corporations that come forward with a Voluntary Self-Disclosure (“VSD”). In updates to the corporate enforcement policy, DOJ’s Criminal Division moved from a “presumption” of declination to a clear promise: in the absence of aggravating circumstances, companies that “come forward, come clean, reform, and cooperate” will receive a declination.[ii] At the same time, and building on the DOJ Corporate Whistleblower Awards Pilot Program, DOJ announced new priority areas eligible for whistleblower rewards, including sanctions evasion and tariff fraud. On the whole, the Department’s approach reflects a significant degree of continuity with the prior Administration’s “carrots and sticks” approach to corporate enforcement. DOJ reported five corporate declinations in 2025, an increase over the past few years. These included a significant declination by the Criminal Division in an FCPA investigation and the first declination under DOJ’s Mergers and Acquisitions (“M&A”) Safe Harbor Policy in a case prosecuted by DOJ’s National Security Division (“NSD”).[iii] These cases reflect the Department’s emphasis on offering declinations if corporations voluntarily report misconduct and there are no aggravating circumstances.

Consistent with DOJ’s stated policy of focusing on prosecutions in target areas, available data suggests a slowdown in criminal corporate enforcement in 2025. A review of public records indicates that in 2025 the Department resolved 21 corporate criminal matters with guilty pleas, five with declinations, five with Non-Prosecution Agreements (“NPAs”), and three with Deferred Prosecution Agreements (“DPAs”).

II. Corporate Enforcement Updates & Announcements

A. Criminal Division Priorities and Updates to the Corporate Enforcement Policy

As discussed in a prior client memorandum, on May 12, 2025, then-Acting Assistant Attorney General of DOJ’s Criminal Division, Matthew R. Galeotti, issued a memorandum titled Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime (the “Galeotti Memorandum”).[iv] The Galeotti Memorandum outlined “the Criminal Division’s enforcement priorities and policies for prosecuting corporate and white-collar crimes in the new Administration.”[v] It called on prosecutors to abide by three core principles—focus, fairness, and efficiency—and announced changes to enforcement policy.[vi] In line with these principles, the Criminal Division announced the following:

First, under the “focus” principle, the Criminal Division will prioritize the investigation and prosecution of “the most urgent criminal threats to the country.”[vii] In doing so it generally suggested a focus on investigations involving fraud and, for the first time, crimes that affect national security, traditionally the responsibility of DOJ’s NSD:

• Fraud: including “trade and customs fraud”; “health care fraud”; and fraud that “victimizes U.S. investors” such as “Ponzi schemes” and “investment fraud.”[viii]
• National Security: including “threats to the U.S. financial system by gatekeepers, such as financial institutions and their insiders that commit sanctions violations or enable transactions by Cartels, TCOs, hostile nation-states, and/or [FTOs]”; “[m]aterial support by corporations to [FTOs],” including cartels; “[c]omplex money laundering, including Chinese Money Laundering Organizations, and other organizations involved in laundering funds used in the manufacturing of illegal drugs”; “[b]ribery and associated money laundering that impact U.S. national interests, undermine U.S. national security, harm the competitiveness of U.S. businesses, and enrich foreign corrupt officials.”[ix]

The Galeotti Memorandum also expanded the scope of the DOJ Corporate Whistleblower Awards Pilot Program, adding priority areas such as sanctions evasion.[x] Galeotti stated that the expansion of the program yielded “credible whistleblower tips across the spectrum of white-collar violations . . . including a number of tips relating to our priority areas—procurement fraud, trade fraud, and sanctions evasion.”[xi]

Second, under the “fairness” principle, the Galeotti Memorandum stated that “[n]ot all corporate misconduct warrants federal criminal prosecution,” and emphasized the importance of “policies that acknowledge law-abiding companies and companies that are willing to learn from their mistakes.”[xii]

One manifestation of this “fairness” principle was the adoption of new, more lenient declination guidelines under the Division’s updated Corporate Enforcement and Voluntary Self-Disclosure Policy (the “CEP”). Under the CEP, the Criminal Division will decline to prosecute companies that “voluntarily self-disclosed the misconduct”; “fully cooperated”; and “timely and appropriately remediated”; as long as “no aggravating circumstances related to the nature and seriousness of the offense” are present.[xiii] The CEP stated that all declinations will be public.[xiv] As noted, in 2025 DOJ reported five declinations.

Third, under the “efficiency” principle, the Galeotti Memorandum directed prosecutors to “take all reasonable steps to minimize the length and collateral impact of their investigations, and to ensure that bad actors are brought to justice swiftly and resources are marshaled efficiently.”[xv] Prosecutors were also directed to “move expeditiously to investigate cases and make charging decisions” and to impose “compliance monitors” only when “a company cannot be expected to implement an effective compliance program or prevent recurrence” without “such heavy-handed intervention.”[xvi]

More recently, on December 4, 2025, Deputy Attorney General Todd Blanche announced a plan to issue a new corporate enforcement policy applicable to all criminal cases across the Department in order to promote consistency across all DOJ components and U.S. Attorney’s Offices.[xvii]

B. Cartels and Transnational Criminal Organizations

On February 5, 2025, her first day as Attorney General, Pamela Bondi issued a memorandum directing federal prosecutors to focus on the “total elimination of Cartels and [TCOs]” and directing the Criminal Division’s FCPA Unit and Money Laundering and Asset Recovery Section to prioritize cartel-related cases.[xviii]

On February 20, the State Department designated multiple Mexican, Salvadorian, and Venezuelan drug cartels as FTOs and Specially Designated Global Terrorists (“SDGTs”). Based on these designations, DOJ can now rely on the “material support” statute (18 U.S.C. § 2339B) in bringing charges against companies or financial institutions. The material support statute, which has broad extraterritorial application, prohibits persons from knowingly providing material support or resources to an FTO, and from attempting or conspiring to do so. Under the statute, “material support” is broadly defined to include any tangible or intangible property, including currency, financial services, and other monetary instruments. The Galeotti Memorandum underscored that “[m]aterial support by corporations to [FTOs], including recently designated Cartels” will be an enforcement priority.[xix]

DOJ’s NSD has used the material support statute and related sanctions laws in the past to bring cases against corporate defendants who make “security payments” and provide other forms of support to designated terrorist organizations.[xx] In 2007, Chiquita Brands International Inc. pleaded guilty and paid a $25 million fine to resolve charges that the company violated economic sanctions by making more than 100 “security payments”—totaling more than $1.7 million—to the Autodefensas Unidas de Colombia, a Colombian paramilitary organization, which the United States government had designated as an FTO and SDGT in 2001. More recently, French cement company Lafarge S.A. and its Syrian subsidiary pleaded guilty and agreed to pay more than $778 million to resolve charges that the company conspired to provide material support to an FTO based on more than $6 million in payments to ISIS and another organization in exchange for protection and permission to operate a cement plant during the Syrian Civil War. These resolutions may be indicative of the types of cases that DOJ could bring in the context of corporate payments to newly designated cartels.

In remarks in September 2025, then-Acting Assistant Attorney General Galeotti highlighted that DOJ is committed to “holding companies accountable when they enable laundering of illicit narcotics proceeds” and that “prosecuting companies, including financial institutions, and individuals that knowingly facilitate criminal conduct such as narcotics trafficking—remains a core part of our practice.”[xxi]

C. The Foreign Corrupt Practices Act

On February 10, 2025, the White House issued its “Executive Order Pausing FCPA Enforcement to Further American Economic and National Security” requiring a 180-day pause on all new FCPA investigations or enforcement actions and a review of all existing FCPA matters. The Executive Order required the Attorney General to issue FCPA enforcement guidelines for future cases. According to statements made by Deputy Attorney General Blanche, by June 2025 DOJ had reviewed all existing cases and closed approximately half of the open investigations.[xxii]

On June 9, 2025, DOJ released its “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” (the “Guidelines”), ending the Executive Order’s FCPA enforcement pause and setting forth DOJ’s new evaluation criteria for FCPA actions.[xxiii] As discussed in our prior client memorandum,[xxiv] the Guidelines outlined four “non-exhaustive factors” for prosecutors to consider when “evaluat[ing] whether to pursue FCPA investigations and enforcement actions:”

• Threats to American Businesses’ Ability to Compete Abroad: The Guidelines advised prosecutors to consider “whether the alleged misconduct deprived specific and identifiable U.S. entities of fair access to compete and/or resulted in economic injury to specific and identifiable American companies or individuals.”[xxv]
• Threats to National Security: The Guidelines instructed prosecutors to focus “on the most urgent threats to U.S. national security resulting from the bribery of corrupt foreign officials involving key infrastructure or assets.”[xxvi]
• Serious Misconduct: The Guidelines instructed prosecutors to avoid penalizing companies for conduct considered to be “routine business practices” or “the type of corporate conduct that involves de minimis or low-dollar, generally accepted business courtesies.”[xxvii]
• Conduct Implicating Cartels and TCOs: The Guidelines instructed prosecutors to prioritize cases with a cartel/TCO nexus, noting that cartels have “infiltrat[ed] into foreign governments across the Western Hemisphere.”[xxviii]

Under the Guidelines, the “initiation of all new FCPA investigations or enforcement actions” must be authorized by senior DOJ leadership and be coordinated through the Fraud Section’s FCPA Unit.[xxix]

D. Trade Fraud

In keeping with the Administration’s focus on tariffs, DOJ announced an intention to prioritize the prosecution of “trade fraud,” including tariff evasion. The Galeotti Memorandum identified “trade and customs fraud, including tariff evasion”[xxx] as a corporate enforcement priority, and, on August 29, DOJ announced the creation of a new “Trade Fraud Task Force” to “aggressively pursue enforcement actions against any parties who seek to evade tariffs and other duties.”[xxxi] The Task Force includes DOJ’s Civil and Criminal Divisions, as well as the Department of Homeland Security. DOJ has already brought civil cases relating to tariff evasion under the False Claims Act (“FCA”) as well as criminal cases under Title 18’s trade fraud and conspiracy provisions.[xxxii]

Criminal Division leadership has noted that particular areas of focus for criminal enforcement include “(1) cases involving long-running efforts to evade hundreds of millions in tariffs, including tariffs on Chinese products, and (2) trade fraud schemes carried out by or with the knowledge of corporate executives.”[xxxiii]

As discussed in greater detail below, on December 18, 2025, DOJ announced the first enforcement actions brought by the Task Force, including a declination for a company, MGI International, that filed a VSD and cooperated with an investigation that led to the guilty plea of the company’s former Chief Operating Officer.[xxxiv] DOJ also announced a $54.4 million settlement in an FCA case against Ceratizit USA to resolve allegations that it improperly failed to pay customs duties on imports of tungsten carbide products imported from China.[xxxv]

E. Healthcare Fraud

In 2025, DOJ intensified its focus on healthcare fraud. This included a July 2, 2025 announcement of the renewal of the DOJ–U.S. Department of Health and Human Services (“HHS”) False Claims Act Working Group, designed to strengthen collaboration between DOJ’s Civil Division and HHS in investigating and prosecuting violations of the FCA. As discussed in our prior client memorandum,[xxxvi] DOJ stated that the working group will expedite investigations and generate new leads by leveraging HHS and HHS-Office of Inspector General (“OIG”) resources, including enhanced data mining and analysis of agency reports, while still encouraging whistleblower participation. Its stated enforcement priorities include Medicare Advantage; drug, device, and biologics pricing (with attention to discounts, rebates, service fees, formulary placement, and price reporting); barriers to patient access (such as network adequacy violations); kickbacks; materially defective medical devices; and manipulation of electronic health records to drive inappropriate Medicare utilization. While the Working Group’s priority enforcement areas include traditional FCA targets, such as fraud and kickbacks, they also cover new and evolving areas under the FCA. For instance, DOJ has not traditionally used the FCA as a vehicle to address “barriers to patient access,” and it remains to be seen how DOJ will pursue FCA enforcement in this area.

F. Digital Assets

On January 23, 2025, President Trump signed an Executive Order on “Strengthening American Leadership in Digital Financial Technology.” The Order declared that it is the Administration’s policy “to support the responsible growth and use of digital assets”—including cryptocurrencies, “blockchain technology, and related technologies across all sectors of the economy”—by, among other things, protecting the ability to lawfully access and use “open public blockchain networks without persecution,” and “protecting and promoting fair and open access to banking services.”[xxxvii] In keeping with the Administration’s broader shift on digital assets policy, DOJ has announced significant shifts in its approach to anti-money laundering enforcement in the digital assets space.

In an April 2025 memorandum (the “Digital Assets Memorandum”), Deputy Attorney General Blanche announced that, in line with the principles of the Executive Order, DOJ “will stop participating in regulation by prosecution in this space.”[xxxviii] The memorandum stated that DOJ will prioritize enforcement related to digital assets against individuals who (i) “cause financial harm” to investors and consumers, or (ii) “use digital assets in furtherance of other criminal conduct, such as fentanyl trafficking, terrorism, cartels, organized crime, and human trafficking and smuggling.”[xxxix] According to the Digital Assets Memorandum, prosecuting the first category of conduct—which includes embezzlement, digital asset investment scams, and misappropriation of funds—is “important to restoring stolen funds to customers, building investor confidence in the security of digital asset markets, and the growth of the digital asset industry.”[xl] The second category involves prioritizing instances where cartels, TCOs, terrorist organizations, SDGTs, and nation states subject to U.S. sanctions use digital assets to “fund their operations and launder the proceeds of their illicit businesses.”[xli]

Notably, the Digital Assets Memorandum stated that, while DOJ will “pursue the illicit financing of these enterprises by the individuals and enterprises themselves, including when it involves digital assets . . . [it] will not pursue actions against the platforms that these enterprises utilize to conduct their illegal activities.”[xlii] DOJ leadership has continued to emphasize that they will not prosecute “developers of neutral tools, with no criminal intent” because of “someone else’s misuse of those tools.”[xliii]

DOJ has stressed a decreased focus on charging regulatory violations in cases involving digital assets absent evidence that the defendant willfully violated the licensing or registration requirement at issue.[xliv] Similarly, unless granted approval by the Deputy Attorney General, prosecutors will not charge violations under conventional financial regulatory statutes—including the Securities Act of 1933, the Securities Exchange Act of 1934, the Commodity Exchange Act, or the regulations promulgated thereunder—if doing so requires DOJ to litigate whether a digital asset is a “security” or “commodity” and alternative criminal charges available, such as mail or wire fraud, are available.[xlv]

As part of these shifts, DOJ has also disbanded two teams that had been focused on cryptocurrency enforcement: the Market Integrity and Major Frauds Unit and the National Cryptocurrency Enforcement Team.[xlvi] The Digital Assets Memorandum stated that DOJ would redirect resources from digital assets enforcement towards “other priorities, such as immigration and procurement frauds.”[xlvii]

III. Significant DOJ Corporate Prosecutions & Resolutions in 2025

A. The Foreign Corrupt Practices Act

Following the publication of its FCPA Guidelines in June 2025, DOJ resolved or initiated three significant corporate FCPA actions. The outcomes were largely based on the CEP factors. In August 2025, DOJ issued a declination to Liberty Mutual Insurance Company (“Liberty Mutual”), despite evidence that Liberty Mutual’s Indian subsidiary paid bribes to officials at state-owned banks in India in exchange for those banks steering their customers to the subsidiary’s insurance products. In contrast, in November 2025, DOJ entered into a DPA with Comunicaciones Celulares S.A. d/b/a TIGO Guatemala (“TIGO”), which is a wholly owned subsidiary of Millicom International Cellular, S.A. (“Millicom”). While Millicom had also filed a VSD, DOJ found that the company did not qualify for a declination or a “near miss” NPA[xlviii] due to aggravating factors, including the continuation of misconduct after the voluntary disclosure and links to narcotrafficking proceeds. Additionally, in October 2025, DOJ indicted SGO Corporation Limited (“Smartmatic”), alleging that the company engaged in a yearslong scheme in violation of the FCPA to obtain business from a foreign elections commission.

Liberty Mutual. As discussed in our prior client memorandum, on August 7, 2025, the Fraud Section of DOJ’s Criminal Division and the U.S. Attorney’s Office for the District of Massachusetts declined to prosecute Liberty Mutual for FCPA violations arising out of conduct by employees of its Indian subsidiary, Liberty General Insurance (“LGI”).[xlix] DOJ found evidence that, from approximately 2017 through 2022, LGI paid almost $1.5 million in bribes to officials at six state-owned banks in India in exchange for the banks referring their customers to LGI’s insurance products, leading to nearly $5 million in profits for LGI.[l] As part of the resolution, Liberty Mutual agreed to disgorge roughly $4.7 million and to continue cooperating with ongoing investigations.[li] DOJ’s declination letter credited: (1) Liberty Mutual’s timely voluntary self-disclosure; (2) its full and proactive cooperation (including with respect to individuals); (3) its timely and appropriate remediation (including an early acceptance of responsibility, a thorough and systematic root cause analysis, and separation from personnel involved in the misconduct); (4) its significant enhancements to compliance and internal controls; (5) the absence of aggravating factors; and (6) its disgorgement of “ill-gotten gains.”[lii] No monitor was imposed.

TIGO. On November 12, 2025, TIGO, a Guatemalan telecommunications service provider, entered into a two-year DPA with DOJ’s Fraud Section and the U.S. Attorney’s Office for the Southern District of Florida to resolve a long-running investigation into violations of the FCPA.[liii] According to DOJ, TIGO engaged in a “pervasive bribery scheme” from at least 2012 through June 2018 involving regular cash payments to Guatemalan legislators to garner “support for legislation that benefitted TIGO” and to “secure improper business advantages.”[liv] According to DOJ, in 2015 TIGO’s parent company, Millicom, filed an initial and voluntary self-disclosure regarding the activities by TIGO and the resulting investigation was closed in 2018. However, in 2020 DOJ “obtained and proactively developed new evidence from sources,” and reopened the investigation. According to DOJ, the renewed investigation revealed “the scope of [TIGO’s] conduct, including that the criminal conduct continued during and after the [Department’s] closure of the first phase of the investigation and involved narcotrafficking proceeds that were used to generate cash for some of the bribe payments.”[lv] Under the DPA, TIGO is required to pay a $60 million criminal penalty and more than $58 million in forfeiture. TIGO is also subject to ongoing reporting and compliance obligations for the two-year period in which the agreement is effective, though no monitor was imposed.[lvi] In determining the appropriate resolution, DOJ credited Millicom’s 2015 self-disclosure and cooperation, granting it “the maximum reduction for cooperation and remediation” under the CEP, but found the case did not qualify for a declination or “near miss” NPA under the CEP because the conduct continued after the initial investigation and the bribery funds were derived, in part, from narcotics trafficking.[lvii]

Smartmatic. On October 16, 2025, DOJ indicted a voting machine company, Smartmatic, with conspiracy to violate the FCPA, money laundering conspiracy, and money laundering in the Southern District of Florida.[lviii] Previously, in August 2024, DOJ indicted three Smartmatic executives, alleging that they paid $1 million in bribes to obtain and retain business from the Philippine Commission on Elections (“COMELEC”).[lix] In October 2025, DOJ issued a superseding indictment adding charges against Smartmatic. According to DOJ, Smartmatic “participat[ed] in a scheme to pay and launder more than $1 million in bribes to a Philippine government official in connection with contracts related to the 2016 Philippine national elections.”[lx] DOJ alleged that the “co-conspirators allegedly created a slush fund by over-invoicing the cost per voting machine supplied for the 2016 Philippine elections” and, to conceal these illicit payments, “used coded language, created fraudulent contracts and sham loan agreements” and routed the payments through bank accounts in Asia, Europe, and the United States.[lxi] The bribes were allegedly paid to secure business from COMELEC, “including the release of favorable value added tax [] reimbursements and other contractual payments for the benefit of [Smartmatic] and its affiliates.”[lxii] The case remains pending.

B. The False Claims Act

In February 2025, Michael Granston, Deputy Assistant Attorney General in the DOJ Civil Division, stated that, “consistent with the new administration’s stated focus on achieving governmental efficiency and rooting out waste, fraud and abuse . . . the department plans to continue to aggressively enforce the False Claims Act.”[lxiii] Consistent with that message, DOJ has maintained a focus on bringing and resolving claims against corporations under the FCA. This has included a focus on traditional FCA areas, including healthcare fraud, as well as a heightened focus on some traditionally less prominent areas, including trade and customs fraud. Here, we highlight a few of the notable resolutions that DOJ reached in 2025.

Walgreens. On April 21, 2025, Walgreens agreed to a civil resolution totaling $300 million—plus a contingent $50 million payable upon a qualifying sale, merger, or transfer before 2032—to resolve allegations that it “illegally filled millions of invalid prescriptions for opioids and other controlled substances in violation of the Controlled Substances Act” and submitted related claims for payment to Medicare and other federal health care programs in violation of the FCA.[lxiv] Specifically, according to DOJ, from approximately August 2012 through March 1, 2023, Walgreens ignored “clear red flags” and knowingly filled unlawful prescriptions, including “excessive quantities of opioids,” “significantly early” refills, and “especially dangerous and abused” combinations of opioids, benzodiazepines, and muscle relaxants.[lxv] Walgreens also allegedly “pressured its pharmacists to fill prescriptions quickly” and withheld critical prescriber data from pharmacists, “preventing pharmacists from warning one another about certain problematic prescribers.”[lxvi]

The settlement resolved four qui tam suits, and relators will receive 17.25% of the FCA recovery. DOJ credited Walgreens with cooperation under FCA guidelines. Walgreens also entered a seven-year memorandum of agreement with DEA and a five-year Corporate Integrity Agreement with HHS-OIG that require enhanced compliance, board oversight, training, and reporting. While the settlement did not provide for a monitor, HHS-OIG required Walgreens to hire an independent organization to review pharmacy claims that Walgreens submits for payment.[lxvii]

Delta Air Lines. On July 15, 2025, Delta agreed to pay $8.1 million to resolve allegations that it violated the FCA by awarding compensation to certain corporate officers and employees in excess of the executive compensation caps imposed as a condition of Delta’s receipt of federal funds under the Department of the Treasury’s Payroll Support Program (“PSP”). The PSP required written agreements with compensation limits for individuals who earned more than $425,000 in 2019, later extended through April 1, 2023.[lxviii] DOJ alleged that between March 2020 and April 2023, Delta inaccurately certified quarterly compliance with PSP compensation limits and failed to notify Treasury upon discovering a breach of the limits, which would have allowed the government to demand a return of these funds.[lxix] Delta settled without admitting liability, resolving a qui tam action in which the relator will receive $850,500 and $100,000 in attorneys’ fees. DOJ noted that there was no allegation that Delta misused PSP funds or violated no-layoff provisions.

Ceratizit USA LLC. On December 18, 2025, DOJ entered into a settlement with Ceratizit USA LLC (“Ceratizit”) to resolve claims that Ceratizit engaged in a duty evasion scheme that violated the FCA.[lxx] According to DOJ, from August 2020 through March 2024, Ceratizit, knowing that certain tungsten carbide products (“TCPs”) were manufactured in China, “misrepresented to [U.S. Customs and Border Protection (“CBP”)] that the products originated in Taiwan,” evading duties on those goods.[lxxi] Ceratizit also allegedly misclassified TCPs as being duty free, failed to mark TCPs with their country of origin, and failed to pay marking duties.[lxxii] Ceratizit agreed to pay $54,400,000, including $27,700,000 in restitution, to resolve these allegations.[lxxiii] This action was originally brought by a qui tam relator.[lxxiv] As noted, this resolution was coordinated through the DOJ’s Trade Fraud Task Force. In announcing the settlement, Assistant Attorney General Brett A. Shumate of the Civil Division stated that DOJ will “zealously pursue those who seek an unfair advantage in U.S. markets by evading customs duties.”[lxxv]

C. National Security

In parallel with the Criminal Division’s new focus on corporate investigations impacting national security, DOJ’s NSD continued to pursue and resolve significant corporate national security investigations. This marks an area of continuity with the prior Administration, which placed a significant emphasis on corporate enforcement in national security matters. Notably, in 2025 NSD issued two declinations in national security cases under the NSD Enforcement Policy for Business Organizations, highlighting the potential benefits for companies that submit VSDs to NSD relating to potentially criminal violations of national security laws.[lxxvi]

Universities Space Research Association. On April 30, 2025, NSD announced that it was declining to prosecute the Universities Space Research Association (“USRA”), a nonprofit research corporation and NASA contractor—its second-ever declination under NSD’s Enforcement Policy for Business Organizations.[lxxvii] According to DOJ, between 2017 and 2020, Jonathan Soong, a program administrator for the USRA, “facilitated the sale and export of flight control and optimization software” subject to export controls to Beihang University in the People’s Republic of China.[lxxviii] Beihang University was on the Commerce Department’s Entity List for its “development of military rocket and unmanned air vehicle systems.”[lxxix] Soong, whose job responsibilities included performing diligence on prospective purchasers and ensuring that USRA’s sales were legal, had previously pleaded guilty to charges arising out of that conduct and was sentenced to 20 months in prison.[lxxx]

In its letter declining to prosecute USRA, NSD stated that it had considered charges for violations of the International Emergency Economic Powers Act (“IEEPA”), the Export Control Reform Act of 2018, Export Administration Regulations, the FCA, as well as statutes prohibiting false statements, wire fraud, and obstruction of justice.[lxxxi] Still, NSD announced that it declined to prosecute based on four factors: (1) the “timely and voluntary self-disclosure of the misconduct,” which was made just days after admission by Soong to outside counsel and “well before” completion of NSD’s investigation; (2) USRA’s “exceptional and proactive cooperation,” which “materially assisted” Soong’s prosecution; (3) the fact that the offense consisted of only four total unlicensed exports; and (4) USRA’s “timely and appropriate remediation,” including employee terminations and discipline, “significantly improving” internal controls, and voluntary restitution.[lxxxii]

White Deer Management, LLC / Unicat Catalyst Technologies, LLC. As discussed in our prior client memorandum, on June 16, 2025, NSD announced that it was declining to prosecute a Houston-based private equity firm, White Deer Management, LLC (“White Deer”), for criminal violations of U.S. sanctions and export control laws committed by a portfolio company that White Deer had acquired, Unicat Catalyst Technologies, LLC (“Unicat”).[lxxxiii] That resolution was the first declination of prosecution of an acquiror for self-disclosing criminal conduct discovered at an acquired entity since the March 2024 publication of DOJ’s M&A Safe Harbor Policy, which established a presumption of a declination for companies that take certain steps to disclose and remediate misconduct in the context of mergers and acquisitions.[lxxxiv]

White Deer acquired Unicat, a Texas-based petrochemical company, in September 2020 and then merged Unicat with a subsequently acquired British manufacturer in April 2021.[lxxxv] According to DOJ, when the new UK-based CEO uncovered a pending transaction with an Iranian customer, the parties canceled the transaction, retained counsel, and discovered that Unicat had been servicing customers in Iran, Venezuela, Syria, and Cuba for years, obtaining $3.33 million from illicit sales.[lxxxvi] According to DOJ, the former CEO and other employees concealed these activities by falsifying export documents, employing bank accounts located in sanctioned countries, and communicating in coded language.[lxxxvii] The former Unicat CEO pleaded guilty to one count of conspiring to violate IEEPA and one count of conspiracy to commit money laundering.[lxxxviii] Unicat entered into a NPA, agreeing to forfeit the $3.3 million in proceeds from its violations of U.S. sanctions and export control laws.[lxxxix]

NSD based its decision to decline prosecution on several factors, including that: (1) the acquisition was “lawful and bona fide”; (2) the disclosure of illicit activity was timely under the circumstances and not otherwise required (and was disclosed “before obtaining a complete understanding” of the misconduct); and (3) the “exceptional and proactive cooperation” by White Deer, including undertaking remedial measures.[xc] NSD found that the presence of certain “aggravating factors,” such as the involvement of Unicat’s upper management, did not alter its conclusion because “the causes of those aggravating factors [we]re no longer present.”[xci]

Cadence Design Systems, Inc. On July 28, 2025, NSD announced that Cadence had agreed to plead guilty in the U.S. District Court for the Northern District of California to conspiracy to willfully violate export controls based on its sale of electronic design automation (“EDA”) tools and related technology to a Chinese military university listed on the Commerce Department’s Entity List.[xcii] As Cadence admitted in its plea agreement, the transfer violated export controls imposed under the Export Administration Regulations (“EAR”).[xciii] As reflected in the plea agreement, from February 2015 to April 2021, Cadence conspired to export EDA tools without a license to a Chinese company despite the fact that its employees, including employees of its Chinese subsidiary, knew that the company was an alias for a Chinese military university that had been listed on the Commerce Department’s restrictive Entity List for using U.S.-made technology to “produce supercomputers believed to support nuclear explosive simulation and military simulation activities” in the People’s Republic of China.[xciv] According to DOJ, Cadence did so without seeking or obtaining the required authorization from the Department of Commerce’s Bureau of Industry and Security (“BIS”) to export items subject to the EAR to entities on the Entity List.[xcv]

Under the plea agreement, Cadence paid a criminal fine of $72,488,507.86, which included a 20% reduction for cooperation and remediation and a $24,832,507.86 offset for civil penalties imposed in a parallel BIS administrative action.[xcvi] DOJ explained that it awarded only partial cooperation credit because Cadence had failed to proactively obtain and disclose certain communications of, and facilitate interviews with, certain China-based employees with relevant information.[xcvii] Cadence’s remediation efforts, including the expansion of compliance and training programs, enhancement of screenings, and addition of experienced personnel, were cited favorably. Cadence will also forfeit $45,305,317.41, and is subject to ongoing cooperation and compliance undertakings.[xcviii]

D. Fraud

Across multiple divisions and U.S. Attorneys’ Offices, DOJ continued to prioritize corporate investigations related to fraud. In 2025, this has included resolutions and actions involving various types of fraud, some of which are more traditional investment or consumer fraud cases and others reflect newer areas of priority, including trade fraud and transnational scams that target U.S. citizens. Notably, in 2025 DOJ announced the largest ever bitcoin seizure in the Prince Group / Chen Zhi matter, which related to cryptocurrency scams conducted by international actors.

American Express Company. On January 16, 2025, the U.S. Attorney’s Office for the Eastern District of New York entered into a NPA with American Express resolving potential wire fraud offenses related to deceptive marketing and inaccurate tax-related advice for two products marketed to small-business customers between April 2018 and November 2021.[xcix] American Express admitted the facts in the statement of facts and agreed to pay $108.7 million, which comprised a $77,696,000 fine (reflecting a 20% discount from the lower end of the Guidelines) and $60,700,000 in forfeiture, with a credit to DOJ Civil Frauds of $30,350,000.[c] DOJ credited American Express’s substantial remedial measures, including terminating employees, ceasing sales of the products, overhauling compliance and audit functions, revamping product approval processes, enhancing sales controls and training, mandating recorded sales lines, and prohibiting tax advice to customers.[ci] The NPA imposes ongoing cooperation and disclosure obligations for the term of the agreement.[cii] No monitor was imposed.

Hino Motors, Ltd. On March 19, 2025, Hino Motors, Ltd. (“Hino”), a Toyota subsidiary, pleaded guilty to a multi-year conspiracy. According to DOJ, between 2010 and 2019, Hino engineers submitted and caused to be submitted applications for engine certification approvals that violated the Clean Air Act. DOJ alleged that Hino engineers altered emission test data and fabricated data without conducting any tests. Per DOJ, “[a]s a result of the fraud,” Hino imported and sold more than 105,000 non-conforming engines between 2010 and 2022.[ciii] The Court ordered a criminal fine of $521.76 million as well as a $1.087 billion forfeiture money judgment against the company. The sentence also included a five-year term of probation, and requirements for Hino to implement a comprehensive compliance and ethics program and reporting structure. Hino received cooperation credit from DOJ for its extensive document collection and interviews, disciplinary actions, and compensation to affected purchasers in related civil litigation, among other efforts.[civ]

Credit Suisse Services AG. On May 5, 2025, Credit Suisse Services AG pleaded guilty in the U.S. District Court for the Eastern District of Virginia to conspiring with U.S. taxpayers to conceal more than $4 billion in assets in at least 475 offshore accounts.[cv] According to DOJ, Credit Suisse assisted U.S. customers in opening offshore accounts and provided offshore private banking services to maintain those accounts, enabling customers to evade their tax obligations.[cvi] To effectuate the scheme, Credit Suisse “falsified records” and “processed fictitious donation paperwork,” among other “fraudulent acts.”[cvii] The plea agreement requires over $510 million in total payments, including a $217,261,890 criminal fine, $46,015,674 in restitution to the IRS, and $108,630,945 in forfeiture, along with a mandatory special assessment.[cviii] The agreement noted concurrent entry into a separate NPA relating to conduct at a former office, Credit Suisse AG Singapore, that UBS voluntarily self-disclosed after the merger of UBS AG Singapore and Credit Suisse AG Singapore.[cix] Because of Credit Suisse’s breach of a 2014 plea agreement and the continuation of misconduct, DOJ refused to credit Credit Suisse’s VSD and much of its cooperation. Nevertheless, DOJ credited Credit Suisse’s remedial efforts, disciplinary measures, and certain aspects of its cooperation.[cx]

Prince Group / Chen Zhi. As discussed in our prior client memorandum, on October 14, 2025, the U.S. Attorney’s Office for the Eastern District of New York charged Chen Zhi, Chairman of Prince Group, with fraud and money laundering in connection with the operation of forced-labor “scam compounds” in Cambodia engaged in fraudulent cryptocurrency investment schemes. United States Attorney Joseph Nocella, Jr. called the Prince Group’s scheme “one of the largest investment fraud operations in history.”[cxi] According to DOJ, trafficked workers were coerced into executing “pig butchering” scams, which involved gaining victims’ trust online, sometimes through romantic scams, and then deceiving them into investing in fake crypto assets. DOJ noted that one such network, based in Brooklyn, laundered about $18 million of illicit proceeds from more than 250 American victims between May 2021 and August 2022.[cxii] DOJ also initiated a related civil in rem forfeiture action seeking approximately 127,271 bitcoin (valued at roughly $15 billion), which is the largest forfeiture action pursued in DOJ history.[cxiii] On January 6, 2026, Chen Zhi was arrested and extradited to China following a months-long investigation by Chinese and Cambodian authorities.[cxiv]

MGI International, LLC. On December 18, 2025, DOJ resolved a criminal investigation into a tariff evasion scheme by declining to charge MGI International, LLC and its subsidiaries, Global Plastics LLC and Marco Polo International LLC (collectively, “MGI”).[cxv] DOJ did criminally prosecute MGI’s former Chief Operating Officer, David Guimond, who has agreed to plead guilty in the U.S. District Court for the District of New Hampshire to conspiring to smuggle goods into the United States.[cxvi] According to the plea agreement, Guimond instructed MGI employees, when importing plastic resin from China, to falsify the country of origin on entry forms submitted to CBP, thereby avoiding duties.[cxvii] In declining to prosecute MGI for this conduct, DOJ credited $6.8 million that Global Plastics and Marco Polo paid in July 2025 to resolve their civil liability under the FCA,[cxviii] and relied on the Criminal Division’s updated CEP.[cxix] DOJ found that the CEP factors favored declination because, inter alia, MGI: (1) timely and voluntarily disclosed the misconduct; (2) cooperated fully and proactively; (3) took prompt and appropriate remediation by (a) disciplining the responsible employees, (b) internally reviewing the misconduct as well as its internal controls, and (c) enhancing its compliance program; and (4) fully repaid the evaded tariffs.[cxx] As noted, this resolution was coordinated through the DOJ’s Trade Fraud Task Force. Deputy Attorney General Blanche stated that this declination “makes clear what the incentives for corporations are to voluntarily self-disclose and remediate identified criminal conduct.”[cxxi]

* * *

[i] Matthew R. Galeotti, Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime, at 2 (May 12, 2025), available here.

[ii] Dep’t of Just., Head of the Criminal Division, Matthew R. Galeotti Delivers Remarks at SIFMA’s Anti-Money Laundering and Financial Crimes Conference (May 12, 2025), available here.

[iii] These declinations were for Liberty Mutual and White Deer, respectively. These declinations are discussed below.

[iv] Paul, Weiss, DOJ Announced New Corporate and White-Collar Enforcement Policies and Priorities, at 1 (May 14, 2025), available here.

[v] Matthew R. Galeotti, Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime, at 2 (May 12, 2025), available here.

[vi] Id.

[vii] Id.

[viii] Id. at 4.

[ix] Id. at 4–5.

[x] Id. at 5.

[xi] Dep’t of Just., Acting Assistant Attorney General Matthew R. Galeotti Delivers Remarks at Association of Certified Anti-Money Laundering Specialists (ACAMS) Conference (September 17, 2025), available here.

[xii] Galeotti Memorandum at 5–6.

[xiii] Dep’t of Just., 9–47.120, Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy, at 1 (May 12, 2025), available here.

[xiv] Id.

[xv] Galeotti Memorandum at 7.

[xvi] Galeotti Memorandum at 7–8; see also Matthew R. Galeotti, Memorandum on Selection of Monitors in Criminal Division Matters, at 1–2 (May 12, 2025), available here (providing updated criteria for the selection of monitors).

[xvii] Max Fillion, Justice Department Prepping Single Policy for All Corporate Criminal Cases, Dow Jones Risk Journal (December 11, 2025), available here.

[xviii] Pamela Bondi, Total Elimination of Cartels and Transnational Criminal Organizations (Feb. 5, 2025), available here.

[xix] Galeotti Memorandum at 4.

[xx] Mark Mendelsohn et al., How to Navigate Risks for Firms on Cartel-Related Activities, Bloomberg Law (June 5, 2025), available here.

[xxi] Dep’t of Just., Acting Assistant Attorney General Matthew R. Galeotti Delivers Remarks at Association of Certified Anti-Money Laundering Specialists (ACAMS) Conference (September 17, 2025), available here.

[xxii] X Post from Todd Blanche (June 10, 2025), available here.

[xxiii] Todd Blanche, Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA) (June 9, 2025), available here (the “Guidelines” or “FCPA Memorandum”).

[xxiv] Paul, Weiss, DOJ FCPA Guidelines End the Enforcement Pause and Shift Focus to U.S. Interests (June 12, 2025), available here.

[xxv] FCPA Memorandum at 2–3.

[xxvi] Id. at 3.

[xxvii] Id. at 3–4.

[xxviii] Id. at 2.

[xxix] Id.

[xxx] Galeotti Memorandum at 4.

[xxxi] U.S. Dep’t of Justice, Departments of Justice and Homeland Security Partnering on Cross-Agency Trade Fraud Task Force (Aug. 29, 2025), available here.

[xxxii] Paul, Weiss, Trump Administration Heightens Enforcement Focus on Tariff Evasion and “Transshipment” (Aug. 25, 2025), available here.

[xxxiii] Dep’t of Just., Acting Assistant Attorney General Matthew R. Galeotti Delivers Remarks at the Global Investigations Review Annual Meeting (September 19, 2025), available here.

[xxxiv] See Dep’t of Just., Justice Department Resolves Criminal Trade Fraud Investigation with Plastic Resin Distributor; Former Executive Agrees to Plead Guilty (Dec. 18, 2025), available here.

[xxxv] Dep’t of Just., Ceratizit USA LLC Agrees to Pay $54.4M to Settle False Claims Act Allegations Relating to Evaded Customs Duties (Dec. 18, 2025), available here.

[xxxvi] Paul, Weiss, DOJ and HHS Reestablish False Claims Act Working Group (July 9, 2025), available here.

[xxxvii] The White House, Strengthening American Leadership in Digital Financial Technology (Jan. 23, 2025), available here.

[xxxviii] Todd Blanche, Ending Regulation by Prosecution Memorandum (Apr. 7, 2025), available here.

[xxxix] Id. at 2.

[xl] Id.

[xli] Id.

[xlii] Id.

[xliii] Dep’t of Just., Acting Assistant Attorney General Matthew R. Galeotti Delivers Remarks at the American Innovation Project Summit in Jackson, Wyoming (Aug. 21, 2025), available here.

[xliv] Digital Assets Memorandum at 3.

[xlv] Id.

[xlvi] Id. at 4.

[xlvii] Id.

[xlviii] Under the CEP, a “near miss” NPA is utilized for cases where a company would have been eligible for a declination, but did not qualify because (1) its self-reporting did not qualify as a VSD; or (2) there were “aggravating factors that warrant a criminal resolution.” Dep’t of Just., 9–47.120, Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy, at 1 (May 12, 2025), available here.

[xlix] Dep’t of Just., Declination Letter to Liberty Mutual Insurance Company (Aug. 7, 2025), available here; Paul, Weiss, DOJ Resolves First Corporate FCPA Case Following Enforcement Pause With Declination to Prosecute Liberty Mutual (Aug. 18, 2025), available here.

[l] Dep’t of Just., Declination Letter to Liberty Mutual Insurance Company (Aug. 7, 2025), available here.

[li] Id.

[lii] Id.

[liii] Deferred Prosecution Agreement, United States v. Comunicaciones Celulares S.A., d/b/a TIGO Guatemala, No. 25-cr-20476 (S.D. Fla. Nov. 12, 2025).

[liv] Id. ¶ 9

[lv] Dep’t of Just., TIGO Guatemala Paid Over $118M To Resolve Foreign Bribery Investigation (Dec. 12, 2025), available here.

[lvi] Deferred Prosecution Agreement, United States v. Comunicaciones Celulares S.A., d/b/a TIGO Guatemala, No. 25-cr-20476 (S.D. Fla. Nov. 12, 2025), ¶ 4(k).

[lvii] Id. ¶ 4(b).

[lviii] Dep’t of Just., Voting Machine Company Charged in Philippine Bribery and Money Laundering Scheme (Oct. 16, 2025), available here; Superseding Indictment, United States v. Juan Andres Donato Bautista, et al., No. 1:24-cr-20343-KMW (S.D. Fla. Oct. 16, 2025).

[lix] The August 2024 indictment also charged the former chair of COMELEC with money laundering for his role in the scheme..

[lx] Dep’t of Just., Voting Machine Company Charged in Philippine Bribery and Money Laundering Scheme (Oct. 16, 2025), available here.

[lxi] Id.

[lxii] Id.

[lxiii] Daniel Wilson, DOJ Official Flags ‘Aggressive’ FCA Approach Under Trump, Law360 (Feb. 20, 2025), available here (emphasis added).

[lxiv] Dep’t of Just., Walgreens Agrees to Pay Up to $350M for Illegally Filing Unlawful Opioid Prescriptions and for Submitting False Claims to the Federal Government (Apr. 21, 2025), available here.

[lxv] Id.

[lxvi] Id.

[lxvii] Dep’t of Health and Human Svcs., Corporate Integrity Agreement with Walgreen Co (Apr. 21, 2025), available here.

[lxviii] Dep’t of Just., Delta Air Lines Settlement Agreement (July 11, 2025), available here.

[lxix] Dep’t of Just., Delta Air Lines Agrees to Pay $8.1M to Settle Alleged False Claims Act Violations Related to Payroll Support Program (July 15, 2025), available here.

[lxx] Dep’t of Just., Ceratizit USA LLC Agrees to Pay $54.4M to Settle False Claims Act Allegations Relating to Evaded Customs Duties (Dec. 18, 2025), available here.

[lxxi] Id.; Settlement Agreement, United States ex rel. Stover v. Ceratizit USA., No. 2:22-cv-12291 (E.D. Mich. Dec. 18, 2025), Dkt. No. 36-1.

[lxxii] Dep’t of Just., Ceratizit USA LLC Agrees to Pay $54.4M to Settle False Claims Act Allegations Relating to Evaded Customs Duties (Dec. 18, 2025), available here.

[lxxiii] Id.

[lxxiv] Id. (citing United States ex rel. Stover v. Ceratizit USA., No. 2:22-cv-12291 (E.D. Mich.)).

[lxxv] Id.

[lxxvi] U.S. Dep’t of Just., NSD Enforcement Policy for Business Organizations (Mar. 7, 2024), available here.

[lxxvii] U.S. Dep’t of Just., Justice Department Declines Prosecution of Company That Self-Disclosed Export Control Offenses Committed by Employee (Apr. 30, 2025), available here.

[lxxviii] Letter from Rachel Craft and Barbara Velliere, DOJ, to Clark Ervin, Counsel at Squire Patton Boggs, (Apr. 23, 2025), available here, at 1.

[lxxix] Id.

[lxxx] Id.

[lxxxi] Id.

[lxxxii] Id. at 2.

[lxxxiii] U.S. Dep’t of Just., Justice Department Declines Prosecution of Private Equity Firm Following Voluntary Disclosure of Sanctions Violations and Related Offenses Committed by Acquired Company (June 16, 2025), available here; See Paul, Weiss, DOJ Announces First Ever Declination of Prosecution of an Acquiring Company for Sanctions Violations Under DOJ’s M&A Safe Harbor Policy (June 20 2025), available here.

[lxxxiv] Id.; For further analysis of the DOJ M&A safe harbor policy, see: Paul, Weiss, DOJ Announces New Department-Wide Mergers & Acquisitions Safe Harbor Policy and Emphasizes Expanded Focus on National Security Corporate Crime (October 6, 2023), available here.

[lxxxv] U.S. Dep’t of Just., Justice Department Declines Prosecution of Private Equity Firm Following Voluntary Disclosure of Sanctions Violations and Related Offenses Committed by Acquired Company (June 16, 2025), available here.

[lxxxvi] Id.

[lxxxvii] Letter from Adam P. Barry and S. Mark McIntyre, DOJ, to Mark Stuckey, CEO of Unicat (Dec. 19, 2024), available here, at 7.

[lxxxviii] See United States v. Mani Erfan, Plea Agreement, 4:24-cr-00401 (S.D. Tex.).

[lxxxix] See Letter from Adam P. Barry and S. Mark McIntyre, DOJ, to Mark Stuckey, CEO of Unicat, (Dec. 19, 2024).

[xc] Letter from Adam P. Barry and S. Mark McIntyre, DOJ to James E. Meneely III, White Deer Management, (Dec. 19, 2024), available here, at 2.

[xci] Id.

[xcii] Dep’t of Just., Cadence Design Systems Agrees to Plead Guilty and Pay Over $140 Million for Unlawfully Exporting Semiconductor Design Tools to a Restricted PRC Military University (July 28, 2025), available here.

[xciii] Dep’t of Just., Cadence Design Systems Agrees to Plead Guilty and Pay Over $140 Million for Unlawfully Exporting Semiconductor Design Tools to a Restricted PRC Military University (July 28, 2025), available here; Information, United States v. Cadence Design Systems, Inc., No. cr-25-00217-EJD (N.D. Cal. July 28, 2025); Plea Agreement, United States v. Cadence Design Systems, Inc., No. cr-25-00217-EJD (N.D. Cal. July 28, 2025).

[xciv] Dep’t of Just., Cadence Design Systems Agrees to Plead Guilty and Pay Over $140 Million for Unlawfully Exporting Semiconductor Design Tools to a Restricted PRC Military University (July 28, 2025), available here.

[xcv] Id.

[xcvi] Plea Agreement, United States v. Cadence Design Systems, Inc., No. cr-25-00217-EJD (N.D. Cal. July 28, 2025); see also Dep’t of Com., Cadence Design Systems to Pay $95 Million Penalty to BIS for Unauthorized Exports to Chinese Entities Tied to Development of Military Supercomputers (July 28, 2025), available here.

[xcvii] Dep’t of Just., Cadence Design Systems Agrees to Plead Guilty and Pay Over $140 Million for Unlawfully Exporting Semiconductor Design Tools to a Restricted PRC Military University (July 28, 2025), available here.

[xcviii] Id.

[xcix] Dep’t of Just., American Express Company Non-Prosecution Agreement (Jan. 16, 2025), available here.

[c] Id.

[ci] Id.

[cii] Id.

[ciii] Plea Agreement, United States v. Hino Motors, Ltd., No. 2:25-cr-20016 (E.D. Mich. Jan. 15, 2025); Information, United States v. Hino Motors, Ltd., No. 2:25-cr-20016 (E.D. Mich. Jan. 15, 2025); Dep’t of Just., Court Sentences Hino Motors Ltd., a Toyota Subsidiary, and Imposes Over $1.6B in Penalties for Emissions Fraud Scheme (Mar. 19, 2025), available here.

[civ] Plea Agreement, United States v. Hino Motors, Ltd., No. 2:25-cr-20016 (E.D. Mich. Jan. 15, 2025).

[cv] Plea Agreement, United States v. Credit Suisse Services AG, No. l:25-cr-00123 (E.D. Va. May 5, 2025).

[cvi] Dep’t of Just., Credit Suisse Services AG Admits to Conspiring with U.S. Taxpayers to Hide Assets and Income in Offshore Accounts and Admits that Credit Suisse Breached Its Prior Plea Agreement (May 5, 2025), available here.

[cvii] Id.

[cviii] Plea Agreement, United States v. Credit Suisse Services AG, No. l:25-cr-00123 (E.D. Va. May 5, 2025).

[cix] Dep’t of Just., Credit Suisse Services AG Admits to Conspiring with U.S. Taxpayers to Hide Assets and Income in Offshore Accounts and Admits that Credit Suisse Breached Its Prior Plea Agreement (May 5, 2025), available here.

[cx] Plea Agreement, United States v. Credit Suisse Services AG, No. l:25-cr-00123 (E.D. Va. May 5, 2025).

[cxi] Paul, Weiss, DOJ and Treasury Undertake Significant Enforcement Actions Targeting Southeast Asian Scam Networks, Underscoring Cyber-Enabled Fraud as an Enforcement Priority (October 21, 2025), available here.

[cxii] Id.

[cxiii] Id.

[cxiv] Helen Regan, Alleged Cybercrime Kingpin Arrested and Extradited from Cambodia to China, CNN (Jan. 8, 2026), available here.

[cxv] Dep’t of Just., Justice Department Resolves Criminal Trade Fraud Investigation with Plastic Resin Distributor; Former Executive Agrees to Plead Guilty (Dec. 18, 2025), available here.

[cxvi] Information, United States v. Guimond, No. 1:25-cr-00098 (D.N.H. Dec. 17, 2025); Plea Agreement, United States v. Guimond, No. 1:25-cr-00098 (D.N.H. Dec. 17, 2025).

[cxvii] Id.

[cxviii] Dep’t of Just., Importers Agree to Pay $6.8M to Resolve False Claims Act Liability Relating to Voluntary Self-Disclosure of Unpaid Customs Duties (July 23, 2025), available here.

[cxix] Dep’t of Just., Justice Department Resolves Criminal Trade Fraud Investigation with Plastic Resin Distributor; Former Executive Agrees to Plead Guilty (Dec. 18, 2025), available here.

[cxx] Id.

[cxxi] Id.