DOJ Fraud Division Rolls Out New Corporate Enforcement Framework

Executive Summary

• What’s new: On October 1, 2026, the DOJ’s National Fraud Enforcement Division issued a directive on corporate enforcement of fraud schemes that provides insight into its priorities and calls for an aggressive, all-tools approach.
• Why it matters: Enforcement priorities include fraud schemes involving the health care industry; government contracts; significant evasion of internal or external revenue; and tariff evasion, importation of goods or services, or forced labor.
• What to do next: Companies should consider pressure-testing compliance programs and internal controls, particularly in the priority areas. If misconduct is identified, they should consider promptly assessing whether to self-disclose, cooperate and remediate.