The Department of Justice has overhauled its white-collar enforcement priorities under President Trump’s second administration, shifting focus from broad-based principles to direct threats against national security and economic stability. This approach stems from leadership changes, budget limitations, and a deliberate emphasis on risks that directly impact U.S. interests. The agency now adopts a more responsive, case-specific strategy rather than pursuing sweeping investigations.
Trade fraud has become a cornerstone of the DOJ’s enforcement agenda. In May 2025, then-Criminal Division head Matthew Galeotti outlined the new direction in an internal memo, stressing fairness and operational efficiency. By August of that year, the agency formalized its commitment by establishing the Trade Fraud Task Force—a collaborative effort with Homeland Security. Under this initiative, the DOJ has pursued criminal cases through the False Claims Act and Section 301 of the Trade Act of 1974, focusing on tariff evasion and customs violations. One of the first major outcomes came in December 2025, when Global Plastics LLC and Marco Polo International LLC settled allegations of falsifying origin declarations to avoid duties on Chinese imports. The settlement totaled $6.8 million.
The crackdown has also expanded to sanctions and export controls, where civil enforcement by the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) often transitions into criminal investigations when intentional misconduct is detected. Companies now face closer scrutiny of distribution channels, high-risk transshipment routes, and payment structures that obscure beneficial ownership. The DOJ has broadened its efforts to include cartels and transnational criminal organizations (TCOs), particularly those involved in drug trafficking, money laundering, or support for designated Foreign Terrorist Organizations (FTOs). In March 2026, the agency charged six Chinese nationals and two companies for drug conspiracies, including allegations of providing material support to an FTO by selling chemical precursors.
Digital currency enforcement remains selective, with the DOJ deprioritizing technical compliance violations but intensifying efforts against fraud involving cryptocurrency. The Scam Center Strike Force, launched in March 2026, has already seized over $630 million in assets linked to “pig butchering” scams originating in Southeast Asia. By February 2026, seizures exceeded $580 million, demonstrating the scale of the operation.
Fraud Task Force Targets Federal Programs
The creation of the National Fraud Enforcement Division in January 2026 signals a broader push to combat fraud against federal programs, healthcare systems, and government procurement. This division aims to recover misused taxpayer funds while maintaining pressure on healthcare fraud and procurement abuses. The initiative reflects the administration’s resolve to address financial misconduct across multiple sectors.
Regulatory agencies beyond the DOJ have also adjusted their enforcement strategies. The Securities and Exchange Commission (SEC) has returned to core fraud investigations, with a sharper focus on cross-border misconduct and foreign private issuers (FPIs). Chairman Paul Atkins has rejected an approach relying on enforcement alone, instead prioritizing fraud and investor harm.
The SEC’s Concept Release on FPIs, published in June 2025, highlighted how the U.S. has become the exclusive or primary trading market for many foreign companies—a development that has intensified scrutiny. In December 2025, President Trump signed the Holding Insiders Accountable Act (HIAA), requiring executives of FPIs to disclose beneficial ownership in their companies’ securities. This measure further tightens regulatory oversight of foreign entities with significant U.S. investor exposure.
Under Acting Chairman Caroline Pham, the CFTC launched a 30-day enforcement sprint in March 2025, encouraging firms to resolve outstanding compliance issues. The effort resulted in six settled cases and $8.3 million in penalties by September 2025, allowing the agency to redirect resources toward more serious investigations.
FinCEN Cuts Off Cartel Money Flows
FinCEN has taken aggressive steps to isolate high-risk actors from the U.S. financial system. In June 2025, it issued orders against three Mexican banks linked to opioid trafficking, cutting off their access to U.S. funds. The agency has since used Section 311 of the USA PATRIOT Act to target entities involved in fentanyl trafficking, virtual-currency scams, and cartel-linked money laundering. Proposed measures against Swiss banks like MBaer Merchant Bank AG in February 2026 indicate an expanding global reach in financial enforcement.
The DOJ’s recent emphasis on healthcare fraud has led to high-profile cases against providers billing federal programs for unnecessary services. In February 2026, a Texas-based clinic agreed to pay $47 million to resolve allegations of submitting false claims for medically unnecessary physical therapy treatments. This settlement marks the largest healthcare fraud resolution of the year, with the DOJ emphasizing that such schemes divert critical resources from legitimate patients.
The DOJ’s intensified focus on Foreign Corrupt Practices Act (FCPA) violations tied to cartel activity has expanded beyond narcotics trafficking to include bribery schemes linked to illicit proceeds. In June 2025, then-Deputy Attorney General Todd Blanche issued guidelines directing prosecutors to prioritize FCPA cases with cartel-related connections. The first major resolution under this directive came in November 2025, when telecommunications provider TIGO Guatemala agreed to a deferred prosecution agreement after admitting to paying bribes to Guatemalan officials.
Court filings revealed that some bribes originated from funds derived from narcotics trafficking, illustrating how cartel financing bleeds into corporate corruption. This case marked the first time the DOJ explicitly connected FCPA violations to transnational criminal organizations, signaling a broader crackdown on financial networks sustaining both bribery and drug operations.
Cartels, Terrorism, and Corporate Fraud Collide
The DOJ’s approach has also extended to cartel-linked money laundering through partnerships with FinCEN and OFAC. In parallel with the TIGO Guatemala case, OFAC imposed sanctions on two Mexican shell companies identified as key conduits for cartel funds, freezing their U.S. assets. The DOJ’s Southern District of Ohio charged six Chinese nationals and two pharmaceutical companies in March 2026 for operating a network that supplied chemical precursors to a designated Foreign Terrorist Organization (FTO).
Prosecutors alleged that the same network laundered proceeds through shell entities in Hong Kong and Malaysia, demonstrating how cartel financing, terrorism funding, and corporate fraud intersect. The case highlighted the DOJ’s willingness to prosecute not just end-users of illicit goods but also the intermediaries who obscure their origins.
FinCEN’s enforcement actions have increasingly targeted cartel-linked financial flows along the U.S.-Mexico border, where bulk cash smuggling and oil trafficking remain persistent risks. In March 2026, the agency issued an alert warning financial institutions about bulk cash repatriation schemes used by Mexico-based transnational criminal organizations (TCOs) to move proceeds into the U.S.
The alert cited cases where TCOs structured cash transfers through unsuspecting money services businesses (MSBs), often disguising the origin as legitimate remittances. FinCEN’s data-driven approach has led to six notices of investigation against MSBs operating near the border, with additional cases referred to the IRS for potential tax evasion probes. A December 2025 operation also resulted in over 50 compliance outreach letters to firms flagged for suspicious activity, reflecting FinCEN’s shift toward proactive supervision.
Beyond cash movements, FinCEN has focused on oil smuggling schemes tied to cartel financing. A May 2025 alert detailed how Mexico-based cartels exploited underregulated fuel distribution networks to smuggle diesel and gasoline into the U.S., often using falsified invoices or third-party brokers to launder proceeds. The agency’s Financial Trend Analysis on cartel-linked illicit finance highlighted how these schemes generate hundreds of millions annually, with proceeds recycled through legitimate businesses or reinvested in narcotics production. FinCEN’s use of Section 311 authority has further isolated high-risk actors, including 10 Mexico-based gambling establishments linked to the Sinaloa Cartel. The orders effectively severed their access to the U.S. financial system, demonstrating how targeted disruptions can undermine cartel revenue streams.
The SEC’s task force on cross-border fraud has begun examining securities law violations by foreign companies with significant U.S. investor exposure, particularly those based in jurisdictions where state influence affects corporate governance. The SEC’s Concept Release on Foreign Private Issuers (FPIs) in June 2025 noted that many FPIs now rely on the U.S. as their primary market, raising concerns about transparency and investor protections. In response, the agency formed a dedicated task force to investigate potential violations, with early focus on firms from China, where regulatory interference and data localization laws pose unique risks. The law applies even when U.S. residents hold a majority stake, provided the issuer meets certain structural criteria, such as foreign-based management or assets.