Edward Nogay – Monitoring Regulations

Eddie is a valuable member of his firm’s White Collar + Government Investigations team with a specific focus on conducting crucial internal investigations and providing defense for top financial institutions when faced with regulatory scrutiny from various authorities including the Securities and Exchange Commission (SEC), the Office of the Comptroller of the Currency (OCC), and the U.S. Department of Justice (DOJ).

Recently, on May 12, 2025, Matthew R. Galeotti, the Head of the Criminal Division at the Department of Justice (DOJ), released important memoranda to the Criminal Division staff outlining the Division’s fresh set of priorities and policies concerning the prosecution of corporate and white-collar crimes as well as the implementation of monitorships. Along with this, the Criminal Division unveiled an updated Corporate Enforcement and Voluntary Self-Disclosure Policy and long-awaited modifications to the Corporate Whistleblower Awards Pilot Program on the same day. This move aligns with the stance taken in prior memoranda issued by U.S. Attorney General Pam Bondi and the current Administration, which have been previously discussed.

These policy changes put a spotlight on the DOJ’s enhanced efforts to combat white-collar and corporate crimes, reflecting a shift towards stricter enforcement and increased whistleblowing incentives. The updated enforcement and corporate policies serve as a guide for the Criminal Division personnel on how to approach investigations and prosecutions in this domain. The new priorities set forth by the Division underscore the importance of holding corporations accountable for their actions and ensuring compliance with the law.

As part of the revised policies, there is a particular emphasis on the use of monitorships to oversee the remediation efforts of corporations embroiled in legal issues, showcasing the DOJ’s commitment to thorough oversight and lasting change. Additionally, the revised Corporate Enforcement and Voluntary Self-Disclosure Policy aims to encourage corporations to come forward voluntarily with any potential violations, offering them the opportunity to cooperate and mitigate potential penalties.

The long-awaited updates to the Corporate Whistleblower Awards Pilot Program are a significant development in incentivizing individuals to report corporate wrongdoing and play a critical role in the DOJ’s enforcement efforts. These updates signal a renewed focus on safeguarding whistleblowers and rewarding them for their contributions to uncovering misconduct.

In conclusion, the updates announced by the Criminal Division at the DOJ reflect a strategic shift towards strengthening the enforcement of white-collar and corporate crimes, emphasizing accountability, compliance, and transparency. These policy changes are critical in shaping the landscape of regulatory enforcement and sending a clear message to corporations about the importance of upholding legal standards and cooperating with authorities to address any breaches. Eddie and his team are prepared to navigate these changes and assist financial institutions facing regulatory scrutiny in this evolving regulatory environment.