Reported by A&O Shearman

(Summary shared below. To read full report, go to: https://www.aoshearman.com/en/insights/cross-border-white-collar-crime-and-investigations-review-2026/keeping-up-with-the-us-evolving-white-collar-crime-enforcement-landscape)

The U.S. white-collar crime enforcement landscape shifted sharply in 2025 under the second Trump administration, with a significant pullback in traditional enforcement activity due to major personnel departures, agency resource reductions, and policy realignments, even though the underlying laws remain unchanged and compliance risk persists. 

A May 2025 Department of Justice memorandum refocused enforcement priorities toward an “America First” agenda that balances prosecuting serious fraud and abuse with avoiding actions that overburden legitimate business, directing prosecutors to target government program fraud, trade and customs fraud, investor and consumer fraud, national security threats tied to financial institutions, complex money laundering, and sanctions violations, among other areas. 

The DOJ also paused and then recalibrated enforcement of the Foreign Corrupt Practices Act with new guidelines emphasizing selective, strategic prosecutions aligned with U.S. interests, and regulatory agencies like the SEC signaled a return to core market integrity enforcement rather than broad compliance-centric investigations. 

Although enforcement actions declined in volume, the review underscores that the enforcement risk remains material, that compliance diligence is still essential, and that shifts in focus and personnel mean the landscape is less predictable rather than less risky for businesses operating in or with the United States.