DOJ Sets Priorities for New National Fraud Enforcement Division

The US Department of Justice has released a memorandum setting the enforcement priorities and organizational structure for its new National Fraud Enforcement Division. The August 13 memorandum identifies the five priority areas where the division will focus its anti-fraud efforts: public trust and financial integrity, healthcare, internal revenue, global trade and commerce, and corporate misconduct. The announcement’s broader significance is that it points to a renewed emphasis by DOJ on white-collar investigations.

To this end, DOJ is centralizing fraud expertise in the new division (NFED or the Fraud Division), hiring and reassigning additional personnel, and investing in data analytics designed to identify and pursue fraud nationwide.

For corporate clients, three themes stand out. First, investigations are as likely to be born of sophisticated data analysis—long a staple of Medicare and Medicaid fraud investigations—as with a whistleblower or traditional agency referral. Second, conduct historically treated as a regulatory, administrative, or civil compliance issue, especially in customs and trade, may increasingly present criminal fraud risk. Third, NFED’s structure should make it easier for DOJ to combine multiple approaches in a single investigation, particularly in the tax space.

NEW FRAUD ENFORCEMENT INFRASTRUCTURE

DOJ created NFED in April 2026 to consolidate fraud-enforcement resources and reduce duplication across the Department. The August memorandum shows the scale of that effort: DOJ expects NFED to have approximately 500 attorneys and staff by August 24 and for it to continue expanding rapidly over the next two years.

The organizational structure includes specialized sections for healthcare fraud, public trust and financial integrity, tax, global trade and commerce, corporate enforcement, national enforcement, and asset recovery, in addition to a National Fraud Detection Center and strategic analysis and litigation-support functions.

DOJ is also formalizing NFED’s expanded authority through a new final rule that transfers jurisdiction over certain healthcare and internal-revenue matters to NFED and authorizes the Fraud Division to prosecute other criminal offenses arising from investigations within its jurisdiction. The rule further permits the attorney general to assign additional matters to NFED, giving the division flexibility to expand investigations beyond the fraud theory that initially brought them within its jurisdiction.

The practical change is not simply that DOJ has identified new priorities. It is reorganizing fraud enforcement around conduct. Per the memo, NFED emphasizes deployment of prosecutors alongside US Attorney’s Offices, coordination across agencies, and use of advanced analytics and financial forensics. That model may allow DOJ to identify anomalous billing, pricing, reimbursement, tax, customs, or procurement activity across datasets and assemble the relevant subject-matter expertise around the resulting investigation.

THE FIVE PRIORITIES

Public Trust and Financial Integrity

Government procurement fraud is a stated “critical priority.” The memorandum identifies defective pricing, bid rigging, self-dealing, bribery, product substitution, and billing fraud, with particular concern where misconduct affects national security or military readiness. The mandate also covers fraud involving student loans, childcare, veterans’ benefits, nutrition programs, disaster relief, small-business programs, and other federal benefits and grants.

Companies receiving or administering federal funds should expect continued scrutiny of certifications, eligibility, pricing, billing, and use of government money. Given DOJ’s historic commitment to corporate and individual prosecutions of procurement fraud, predating NFED’s creation, companies should expect that civil inquiries and False Claims Act (FCA) investigations may be paired with parallel criminal investigations.

Healthcare Fraud

Healthcare remains a centerpiece of DOJ fraud enforcement, namely telemedicine, Medicare and Medicaid fraud, controlled-substance diversion, home health and hospice fraud, and deceptive marketing of unsafe healthcare products and services. Per the memorandum, DOJ will expand the Health Care Fraud Strike Force model using additional personnel, analytics, and technology. The healthcare enforcement scale is already significant: DOJ’s June 2026 National Health Care Fraud Takedown involved charges against 455 defendants in alleged schemes exceeding $6.5 billion.

The Fraud Division is also pairing aggressive individual enforcement with corporate disclosure incentives. In July, DOJ declined to prosecute Campus Eye Management after the company voluntarily self-disclosed alleged healthcare fraud and kickback conduct, cooperated, remediated, and agreed to compensate victims, while separately charging an executive.

The matter provides an indication of how the Fraud Division may apply DOJ’s Departmentwide Corporate Enforcement and Voluntary Self-Disclosure Policy in practice.

Internal Revenue

The Fraud Division will integrate criminal tax enforcement into its broader anti-fraud mission, using tax expertise, analytics, and financial forensics to both pursue standalone tax schemes and identify tax offenses arising from other fraud proceeds. Companies and individuals should therefore anticipate that investigations originating in healthcare, procurement, benefits, or other fraud may develop additional tax and asset-recovery dimensions.

This development may represent a sea change in white-collar investigations. Previously, criminal tax investigations were administered by the now-defunct Tax Division, which created logistical challenges for white-collar prosecutors seeking to pursue tax charges. The inclusion of criminal tax prosecutors within NFED will make it easier for prosecutors in a range of white-collar cases to obtain tax returns and may lead to the addition of tax-related charges in traditional white-collar prosecutions.

Global Trade and Commerce

Trade enforcement may be one of the most consequential priorities for companies. The memorandum identifies a focus on illicit transshipment, country-of-origin fraud, undervaluation to evade duties, sanctions evasion, and forced-labor supply chains. The Fraud Division’s Global Trade & Commerce Enforcement Section will operate alongside the cross-agency Trade Fraud Task Force, which DOJ announced has already surpassed $1 billion in civil and criminal recoveries, penalties, forfeitures, and publicly charged losses since its August 2025 launch.

Recent matters show the range of available tools. In May 2026, Perfectus Aluminum and related entities agreed to pay $549.5 million to resolve civil FCA allegations involving evasion of antidumping and countervailing duties; the underlying conduct had also generated prior criminal convictions. DOJ has separately emphasized that the Trade Fraud Task Force’s mandate can reach importers, brokers, distributors, commercial end users, and other supply-chain actors that knowingly benefit from merchandise imported contrary to law.

Companies should accordingly treat customs classification, valuation, country of origin, tariffs, and forced-labor compliance as potential white collar risks, not solely administrative matters.

Corporate Misconduct

The memorandum states that the Fraud Division has a “strong pipeline” of corporate matters and announces the prosecutors will focus on anti-fraud corporate enforcement alongside a dedicated Corporate Enforcement Section.

At the same time, DOJ reiterates that companies can receive substantial benefits for voluntary self-disclosure, cooperation, and remediation. That combination suggests continued corporate enforcement coupled with a premium on early detection and rapid escalation of potential misconduct.

WHAT MAY COMPANIES EXPECT TO SEE GOING FORWARD?

• Expect more data-originated investigations. The National Fraud Detection Center, cross-agency data sharing, and the Fraud Division’s emphasis on analytics may allow DOJ to identify potential misconduct before receiving a conventional referral or whistleblower complaint.
• Regulatory issues may carry greater criminal-fraud risk. Trade and customs enforcement provides the clearest example, but the same convergence is evident in healthcare reimbursement, government contracting, benefits programs, and tax.
• Traditional white-collar cases may increasingly carry tax exposure. Integrating criminal tax prosecutors into NFED may make it easier for DOJ to pursue tax-related charges alongside traditional fraud offenses, increasing potential tax exposure in investigations that do not begin as tax matters.
• Investigations may become more cross-disciplinary. Centralization should make it easier for DOJ to combine criminal fraud, tax, FCA, forfeiture, money-laundering, and other authorities and coordinate Main Justice, US Attorney’s Offices, and investigative agencies.
• Detection speed matters. As government analytics improve in concert with DOJ continuing to offer disclosure incentives, companies in priority sectors should assess whether compliance monitoring uses available internal data effectively and whether potential issues are escalated quickly enough to preserve voluntary-disclosure options.

The August memorandum is more than a list of enforcement priorities. It describes an enforcement infrastructure designed to centralize expertise, generate cases through data, and bring multiple civil and criminal tools to bear on the same conduct.

Companies in healthcare, government contracting, international trade, and other sectors with substantial interaction with federal programs or regulators should consider whether their compliance programs, data monitoring, and investigation protocols are calibrated to that model.