New Fraud Division Flexes Might in Latest Enforcement Policy, Law360
2026年10月08日Partner Sandra Moser spoke with Law360 about the US Department of Justice’s National Fraud Enforcement Division’s new corporate enforcement policy, which outlines prosecutorial priorities, factors guiding corporate charging decisions, and a more centralized approach to fraud investigations and resolutions.
Sandra noted that the directive is “a bit of flex,” and signals the new division’s expanding capabilities and its intention to manage corporate fraud matters independently, including oversight of corporate criminal resolutions.
“It’s saying, ‘We’re handling this in-house,’” she said. “They’re making it clear that they will not need to outsource this to the former [criminal] Fraud Section, which has really been the primary driver of corporate resolution over many years.”