What the DOJ’s New Enforcement Memo Really Means for Financial Service Firms
In May 2025, the U.S. Department of Justice unveiled its “Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime” memorandum, laying out a more targeted—but no less rigorous—enforcement agenda. With the change in administrations, some market participants and even corporations have suggested that the DOJ and financial regulators might “take the foot off the gas.” In our view, however, this would be a misreading of the DOJ’s clear message: while prosecutorial tactics may shift toward higher-impact cases and incentivizing self-disclosure, zero tolerance remains for market abuse, insider trading, money laundering, and related misconduct—across TradFi, CeFi, and DeFi alike.
In response to the DOJ’s renewed emphasis on vigilance and evolving enforcement priorities, StarCompliance (Star) is answering the call—delivering solutions that help firms strengthen oversight, enhance accountability, and stay ahead of regulatory expectations.
DOJ’s Core Priorities & the Star Perspective
1. Market Manipulation & Insider Trading
DOJ: Pursue schemes that distort prices or exploit material, non-public information, from equity pump-and-dumps to token-listing insider tips.
Star: Automated, real-time trade surveillance is essential. Star’s pre-clearance rules and pattern-recognition engines flag suspicious activity before it escalates, directly aligning with the DOJ’s emphasis on early detection and swift action.
2. Digital-Asset Fraud (CeFi & DeFi)
DOJ: Treat crypto exchange fraud, misappropriations, and DeFi rug-pulls with the same vigor as traditional securities offenses—while still promoting lawful innovation.
Star: Robust wallet and transaction monitoring provides the on-chain visibility regulators expect, helping firms spot abnormal flows, insider trades on new token listings, and unauthorized asset movements.
3. Conflicts of Interest & Gatekeeper Accountability
DOJ: Hold individuals—bankers, brokers, gatekeepers—responsible when personal interests override fiduciary duties.
Star: A centralized tool to manage employee Conflicts of Interest ensure all outside activities, investments, and political contributions are disclosed, approved, and refreshed—preventing the very abuses the DOJ has signaled it will target.
4. Incentives for Self-Policing
DOJ: Reward firms that voluntarily self-report, cooperate, and remediate with reduced or even declined charges.
Star: Comprehensive audit trails and reporting dashboards make self-disclosure straightforward. When firms can demonstrate they’ve caught, investigated, and remediated issues internally, they stand to benefit from the DOJ’s fairness tenet.
Maintaining a Critical Eye
This DOJ memo does not signal a relaxation of enforcement. Rather, it underscores the need for precision—focusing resources on the most damaging misconduct while encouraging strong compliance cultures. Financial services firms should continue:
- Vigilant insider-trading controls and market-manipulation surveillance
- Rigorous MNPI management and deal-wall protocols
- Ongoing communications monitoring to catch early warning signs
- Regular conflicts of interest reviews and outside-activity audits
By embedding these capabilities into daily workflows—rather than treating them as periodic check-the-box exercises—firms can both deter misconduct and demonstrate the proactive, self-policing environment that the DOJ’s new policy rewards.
Next Steps
- Assess your current surveillance, MNPI, conflict, and communications programs against the DOJ’s sharpened priorities.
- Enhance your controls with real-time, automated tools that flag and escalate potential issues immediately.
- Document and report internally discovered violations to leverage the DOJ’s incentives for voluntary self-disclosure.
Star stands ready to help firms navigate these expectations—ensuring you neither ease up nor overinvest but strike the precise balance the DOJ now demands. To learn more about Star’s SaaS-basements employee compliance solutions, schedule a personalized demo here.
The Compliance Officer’s Guide To Employee Compliance
