The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu The leading online blog in the fields of corporate governance and financial regulation. Wed, 07 Oct 2026 13:59:50 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.11 https://corpgov.law.harvard.edu/wp-content/uploads/2024/02/cropped-photography-4-e1706898544564-1-32x32.png DOJ Provides New Roadmap for Corporate Fraud Enforcement – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 DOJ Provides New Roadmap for Corporate Fraud Enforcement https://corpgov.law.harvard.edu/2026/10/07/doj-provides-new-roadmap-for-corporate-fraud-enforcement/?utm_source=rss&utm_medium=rss&utm_campaign=doj-provides-new-roadmap-for-corporate-fraud-enforcement https://corpgov.law.harvard.edu/2026/10/07/doj-provides-new-roadmap-for-corporate-fraud-enforcement/#respond Wed, 07 Oct 2026 11:30:13 +0000 https://corpgov.law.harvard.edu/?p=184195?d=20261006155101EDT Posted by Alex Hastings, Sandra Moser, and Amanda Robinson, Morgan Lewis & Bockius LLP, on Wednesday, October 7, 2026
Editor's Note:

Alexander B. Hastings, Sandra Moser, Amanda B. Robinson are Partners at Morgan Lewis & Bockius LLP. This post is based on a Morgan Lewis memorandum by Mr. Hastings, Ms. Moser, Ms. Robinson, and Emily Ahdieh.

Key Takeaways

  • More transparency into enforcement decisions: DOJ’s National Fraud Enforcement Division has identified 10 factors that will receive significant weight, including management involvement, concealment, duration, financial harm, geographic scope, and impact on government programs, among others.
  • Corporate enforcement is becoming more centralized: The Fraud Division’s new Corporate Enforcement Section will coordinate corporate investigations and oversee compliance with corporate resolutions.
  • Early detection and disclosure are increasingly important: Increased use of technology, data analytics, and whistleblower incentives may allow DOJ to identify potential fraud earlier. Companies, particularly in healthcare, government contracting, tax, and trade, should ensure potential misconduct is identified and escalated quickly enough to assess remediation, cooperation, and voluntary disclosure options.

The US Department of Justice’s National Fraud Enforcement Division (Fraud Division) has issued a new directive detailing how its prosecutors will approach corporate investigations and enforcement actions across the division’s healthcare, government contracts, tax, and trade fraud priorities.

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