Holland & Knight·WHITE COLLAR / INVESTIGATIONS

DOJ Fraud Division Directive 26-12 Sets Corporate Enforcement Priorities

On October 1, 2026, AAG Colin McDonald issued Directive 26-12 on corporate enforcement in the fight against fraud, resetting the DOJ Fraud Division's stated priorities and procedures.

What is reported: on October 1, 2026, Assistant Attorney General Colin McDonald issued Directive 26-12, titled "Corporate Enforcement in the Fight Against Fraud," establishing new enforcement priorities and procedures for the U.S. Department of Justice's Fraud Division. The cluster contains a single, truncated source summarizing the directive, so its operative text, any accompanying manual or policy guidance, and the specific priority areas it names are not in evidence here.

Why sophisticated counsel should care: a written division-level directive of this kind is the kind of internal policy document that can shape charging posture, cooperation credit, and the treatment of self-reported misconduct — the levers corporate counsel and compliance teams rely on when deciding whether and how to approach prosecutors. Confirming whether it supersedes or supplements existing department and Fraud Division corporate enforcement policy is the first task, not an assumption.

Concrete next steps: obtain and read the full directive and any implementing guidance; compare its stated priorities against current internal investigation and disclosure protocols; and reassess escalation thresholds for internal reporting and voluntary disclosure. Watch for follow-on announcements, charging examples, or commentary testing how the directive is applied. Individual provisions should be verified against the primary text before any reliance.

doj-fraud-divisioncorporate-enforcementenforcement-prioritiesvoluntary-disclosurecompliance-programsjustice-department-directive
Read the original firm alert → Tuesday, October 6, 2026

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