EDPA Ramps Up Its White-Collar Enforcement Framework

In September 2025, the U.S. Attorneys’ Office for the Eastern District of Pennsylvania (EDPA) announced that it would be implementing a White-Collar Justice Program to strengthen its white-collar enforcement framework.

Among other things, the program will “empower Assistant United States Attorneys to aggressively pursue complex investigations and significant new matters on their own initiative.”

This announcement demonstrates another step in federal districts ramping up their white-collar enforcement efforts while encouraging robust procedures for compliance and self-disclosure. This is a trend several years in the making: in September 2022, then-Deputy Attorney General Lisa Monaco directed U.S. attorneys and others within the DOJ to review their policies on corporate voluntary self-disclosure, and to draft and share a formal written policy to incentivize such self-disclosure, if one was lacking.

Since then, multiple offices—including the Southern District of Florida, the Eastern District of New York, the District of New Jersey, the District of D.C., and the Central District of California—have implemented programs consistent with this directive, following the core principles set out in Monaco’s September 2022 memorandum. Absent the presence of aggravating factors, the DOJ will not seek a guilty plea where a corporation has voluntarily self-disclosed, fully cooperated, and timely and appropriately remedied the criminal conduct.

More recently, Matthew R. Galeotti, head of the DOJ Criminal Division, issued a Memorandum in May 2025 that emphasized fairness and efficiency in prosecuting corporations and individuals alike. Such commentary suggests that though enforcement in this area remains a high priority for the DOJ, voluntary self-disclosure can ameliorate a dire situation.

The EDPA program involves a multi-pronged approach of policies and programs to support its white-collar crime enforcement. Among these policies and programs are:

• a Corporate Transparency Initiative (CTI) to incentivize companies to voluntarily disclose potential criminal conduct;
• the EDPA’s participation in the DOJ’s Corporate Whistleblower Awards Pilot Program, implemented by the Criminal Division, which may monetarily award individual whistleblowers who provide original and truthful information about corporate misconduct that results in a successful forfeiture; and
• a Government Fraud Alliance (the “Alliance”), formally instituted in September 2025, focusing on increasing the use of the federal False Claims Act (FCA) to resolve cases.

We explore each prong of the EDPA White-Collar Justice Program below.

Corporate Transparency Initiative

The EDPA’s CTI will “broaden the pipeline of high-quality white-collar referrals”—promoting integrity, ethics, and accountability in the private sector while “deterring fraud, corruption, and abuse of power.” According to the announcement, while the Initiative “relates to the Criminal Division’s May 12, 2025, Memorandum” regarding white-collar crime, it is “independent of any procedure or protocol set forth by the Criminal Division at Main Justice.” The CTI will include external outreach to stakeholders and incentivizes companies to voluntarily self-disclose potential criminal conduct to the EDPA. Disclosures deemed eligible by the EDPA may receive substantial benefits. For instance, the EDPA:

• will forego seeking a criminal guilty plea against the entity making the disclosure for the conduct at issue; and
• will forego imposing a criminal penalty that is more than 50 percent below the low end of the fine range set forth in the U.S. Sentencing Guidelines, and in some cases, the office will not seek a criminal penalty at all.

In determining eligibility, the EDPA will conduct a careful and individualized assessment to determine whether an entity’s disclosure qualifies as a voluntary self-disclosure under the program, based on the following criteria:

• voluntariness: the disclosure is made voluntarily by the company (preexisting obligations do not qualify);
• timeliness: the disclosure must be made
  • prior to an imminent threat of disclosure or government investigation;
  • prior to the misconduct being publicly disclosed or otherwise known to the government; and
  • within a reasonably prompt time after the company becoming aware of the misconduct, with the burden being on the company to demonstrate timeliness;
• thoroughness: the disclosure must include all relevant facts concerning the misconduct that are known to the company at the time of disclosure.

If disclosures implicate civil liability under the False Claims Act, the EDPA will follow the DOJ’s “Guidelines for Taking Disclosure, Cooperation, and Remediation into Account in False Claims Act (FCA) Matters” pursuant to Section  4-4.112 of the Justice Manual.

As EBG reported in April 2024, the DOJ Criminal Division previously launched a pilot program on voluntary self-disclosures for individuals, which created avenues for individual participants in certain types of corporate misconduct to self-disclose the misconduct, cooperate with authorities and pay any applicable compensation, restitution, and disgorgement in exchange for a non-prosecution agreement (NPA).

DOJ Whistleblower Awards Program

The EDPA’s White-Collar Justice program includes participation in the DOJ’s Whistleblower Awards Pilot Program (“Pilot Program”), a three-year initiative implemented by the Criminal Division’s Money Laundering and Asset Recovery Section in 2024. Recognizing the role that qui tam whistleblowers play in successful enforcement of civil FCA cases and in other contexts within the federal government, the DOJ has sought to fill the gaps in additional potential enforcement areas. As EBG reported in March 2024 and August 2024, an individual who provides original and truthful information (in writing, pursuant to certain conditions) about certain corporate misconduct that results in a successful forfeiture may be eligible for a monetary award. For purposes of the Pilot Program, relevant misconduct may include, but is not limited to:

• certain crimes by financial institutions;
• foreign corruption involving misconduct;
• domestic corruption involving misconduct;
• health fraud schemes involving private insurance plans;
• fraud against the United States in connection with federal funds contracting or federal programs not involving health care or illegal health care kickbacks (typically covered by the FCA);
• violations related to trade, tariff, and customs fraud;
• violations related to federal immigration law; and
• violations related to sanctions offenses, material support of terrorism, or cartels and transnational criminal organizations.

Government Fraud Alliance

Under the EDPA’s new Government Fraud Alliance, the criminal and civil divisions of the EDPA will work together with federal law enforcement partners to immediately review every FCA qui tam filing or whistleblower complaint to ensure that any allegation of fraud against the United States is thoroughly examined from all enforcement angles. As EBG has previously reported, the DOJ is promising aggressive use of the FCA, both in traditional areas, such as health care fraud against the government, and in unchartered ways, including the enforcement of antidiscrimination statutes and prohibitions on gender-affirming care—areas receiving more recent attention from the current administration.

Takeaways

The EDPA’s announcement of its White-Collar Justice Program emphasizes a “culture of proactive target selection” by fostering “self-agency and autonomy for prosecutors to identify and investigate wrongdoing[.]” In this way, prosecutors are emboldened to continue aggressive pursuit of fraud against the United States, while also rewarding activity that can aid these efforts.

The bottom line for companies and individuals is that the present DOJ and individual U.S. Attorney’s Offices will continue to take enforcement of corporate crimes seriously, particularly in the health care space. Companies need to be mindful of the expanding avenues and incentives available to whistleblowers and individuals to report wrongdoing when evaluating compliance programs, when assessing potential fraud or wrongdoing within the company, and when determining how to efficiently identify, address, and rectify any such wrongdoing.

Now is the time to review your company’s policies and procedures, including (but not limited to) any policies and procedures regarding:

• regulatory compliance;
• employee compliance training;
• internal auditing procedures;
• reporting hierarchies;
• internal investigations and risk management procedures;
• company information on personal devices and in third-party messaging applications;
• executive compensation;
• data retention;
• the issuance of document holds;
• the appropriate steps if any employees or business associates receive government touches about the company; and
• the appropriate steps if the company receives an investigative demand or subpoena.

If you have questions about how to tackle these issues or would like assistance in evaluating the adequacy of your company’s policies and procedures, please reach out to the authors.

Epstein Becker Green Staff Attorney Ann W. Parks contributed to the preparation of this post.