In a significant policy shift under the Trump administration, the U.S. Department of Justice (DOJ) recalibrated its enforcement priorities to focus more heavily on transnational crime and healthcare-related fraud, and less on traditional white-collar offenses. This reorientation, led by Attorney General Pam Bondi and senior DOJ officials, represents not just a change in prosecutorial emphasis but a broader ideological shift in how the federal government approaches criminal enforcement.

From Corporate Misconduct to Crimes with Clear Victims

One of the most striking developments under this realignment has been the DOJ’s pivot away from high-level corporate prosecutions, particularly cases involving foreign bribery, public corruption, and securities fraud, in favor of cases that involve identifiable victims. These include fraud schemes targeting vulnerable populations, such as the elderly, and healthcare fraud that affects both patients and taxpayer-funded programs like Medicare and Medicaid.

Rather than pursuing complex white-collar cases where the harm may be diffuse or abstract, the DOJ is signaling that it will prioritize prosecutions that offer clearer narratives of wrongdoing and victimization. This change not only alters the enforcement landscape for corporations, it also impacts how compliance officers, general counsel, and healthcare providers assess their risk.

Heightened Focus on Healthcare Fraud and Opioids

The Trump-era DOJ made healthcare fraud a cornerstone of its enforcement efforts. This includes aggressive pursuit of:

· Fraudulent Medicare and Medicaid billing practices

· Kickback arrangements involving healthcare providers and pharmaceutical companies

· Unlawful opioid prescription schemes contributing to the national addiction crisis

This heightened scrutiny is particularly relevant for providers operating in high-volume specialties or cash-based clinics, where billing practices can easily trigger scrutiny. The message is clear. Healthcare providers and affiliated entities are now squarely in the DOJ’s crosshairs.

Consideration of Political and Economic Ramifications

Another notable shift under this enforcement model is the DOJ’s increased willingness to consider broader political and economic factors when deciding whether to prosecute. Defendants have found a more receptive audience for arguments that prosecutions may be politically motivated or that aggressive enforcement may negatively impact national security or economic interests.

This approach aligns with a more pragmatic and, at times, politically sensitive style of enforcement. It also introduces new strategic considerations for defense counsel, who may find

greater traction in framing legal arguments around collateral consequences and public policy implications.

Leadership-Driven Prioritization

Attorney General Bondi’s leadership has ushered in key personnel changes within the DOJ, aligning the Department’s internal structure with its new priorities. These changes reinforce the top-down commitment to reallocating resources toward cases involving transnational crime, sanctions violations, and healthcare-related fraud, rather than more traditional white-collar investigations.

Takeaways for Healthcare and Corporate Clients

For healthcare professionals, corporate officers, and compliance leaders, this realignment underscores the need for vigilance in areas newly prioritized by the DOJ. Providers should:

· Audit their billing and coding practices regularly

· Reassess referral arrangements and compensation structures for compliance with federal fraud and abuse laws

· Ensure clear documentation of medical necessity, particularly in pain management and opioid prescribing

Call to Action: Don’t Wait for a Subpoena to Get Compliant

If your organization operates in a high-risk sector such as durable medical equipment (DME), diagnostic labs, pharmacies, or remote patient monitoring, the time to act is now. The DOJ’s renewed focus on these areas means that enforcement is not a distant possibility. It is a growing likelihood. A proactive compliance audit of your records, billing protocols, marketing materials, and financial relationships can uncover issues before they become liabilities.

Our team regularly conducts internal audits for clients who want to identify and resolve red flags before they draw government scrutiny. Whether you are preparing for growth or concerned about your exposure, a comprehensive legal review can help you stay ahead of enforcement trends and protect your business.