I. Introduction: More Clarity, But Not a Complete Roadmap

On June 10, Matthew Galeotti, the Head of the U.S. Department of Justice’s (DOJ) Criminal Division, delivered remarks at an event hosted by the American Conference Institute,[1] in which he discussed recent updates to the division’s Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP).[2] The revisions mark the new administration’s most detailed articulation to date of what companies can expect when they come forward to disclose misconduct to the Criminal Division. As Galeotti reiterated in his remarks,[3] the new CEP focuses on three core updates: a streamlined voluntary self-disclosure framework, tighter limits on corporate monitorships, and new whistleblower incentives and policies—including a carveout that allows companies to retain eligibility for a declination even when DOJ learns of misconduct through an internal report.

These are meaningful changes meant to address longstanding concerns raised by corporations about opacity, inconsistency, and surprise in DOJ’s corporate enforcement outcomes. By clarifying expectations around self-disclosure, cooperation, and remediation, the revised CEP seeks to offer companies clearer incentives and a more structured pathway to resolution. But those incentives come with critical caveats—and despite the appearance of predictability, companies should proceed with caution.

As we explain in this article, one of the most important limitations is jurisdictional: the CEP applies only to corporate criminal matters handled by DOJ’s Criminal Division, not to the Department as a whole. This critical distinction is often overlooked but carries major implications for entities considering disclosure. Most corporate investigations are led not by the Criminal Division but by one of the 93 U.S. Attorney’s Offices (USAOs), which retain significant autonomy and are not bound by the CEP—even if they occasionally follow its framework or coordinate with the Criminal Division. These offices often delegate substantial authority to line prosecutors, and may impose different disclosure standards, take a narrower view of cooperation, or be more inclined to require a monitor.

As a result, companies disclosing misconduct to DOJ components beyond the Criminal Division under the assumption that CEP protections apply may find themselves facing an audience that does not view the policy as applicable or even relevant. That risk is compounded in matters involving cross-agency disclosures, where it may be unclear at the outset which part of DOJ—a Main Justice component, a USAO, or some combination—will ultimately assert control over an investigation. DOJ also has no inherent authority, under the CEP or any other policy, to bind the independent enforcement powers of other federal, state, or foreign regulatory bodies, adding an additional level of complexity to the self-disclosure calculus. For companies, the result is that a strategic decision to self-disclose—made in line with the CEP—may still produce a materially different outcome depending on which DOJ office handles the matter and which non-DOJ enforcement authorities are involved.

And jurisdiction is only one of several uncertainties. Despite the CEP’s revamped structure, the revised policy, in and of itself, leaves open critical questions about how prosecutors in the Criminal Division will evaluate “aggravating circumstances,” determine what qualifies as timely disclosure, and assess how companies can meet the demanding threshold for “full” cooperation. The CEP’s newly formalized whistleblower carveout is a step forward in some respects, but it also introduces tight timelines and ambiguity about when the clock starts ticking.

This article seeks to place the CEP in the broader enforcement context and offers a deeper look at some of the policy’s potential gaps. While self-disclosure remains a powerful tool, companies should approach the revised policy with a clear-eyed view of what it offers—and what it doesn’t. And as the next section explores, the limits of DOJ-wide application aren’t just a footnote to the policy—they’re a fundamental strategic concern.

II. The CEP’s Jurisdictional Limits Within DOJ and Broader Multijurisdictional Considerations

A. Putting the CEP and Its Potential Impacts in Context Within the Broader DOJ Landscape

Companies considering the implications of the updated CEP should bear in mind that the policy’s reach is limited with respect to DOJ’s overall corporate enforcement landscape. Although the Criminal Division has in the past exercised outsized influence with respect to corporate enforcement, there are compelling reasons—structural and resource-driven—for companies to maintain a clear understanding of not only what the CEP does, but also what it does not do. Simply put, the CEP does not bind all of DOJ. Rather, by its own terms, the CEP applies only to DOJ’s Criminal Division based in Washington, D.C. DOJ comprises more than 40 components, including several litigating divisions at Main Justice (in addition to the Criminal Division) and the collection of 93 independent USAOs.[4] Other Main Justice components routinely promulgate and update their own enforcement polices, which operate in parallel with the Criminal Division’s CEP. For example, the Antitrust Division and National Security Division continue to maintain their own corporate enforcement policies.[5] Likewise, the Environment and Natural Resources Division outlined its enforcement policy over 30 years ago in 1991—a policy that remains on the books,[6] and which was updated with a component-specific voluntary self-disclosure policy in 2023.[7] Each of these policies is distinct from the Criminal Division’s CEP, creating variability in enforcement outcomes against corporate entities depending on the specific subject matter (or matters) of the investigation.

The Criminal Division’s recent implementation of changes to its CEP also comes amidst an unprecedented reduction in the division’s enforcement authority in key areas, including, most notably, a wide-ranging pause in Foreign Corrupt Practices Act enforcement[8]—a longtime crown jewel of the Criminal Division’s Fraud Section. Attorney General Pam Bondi also imposed significant restrictions on the component’s Money Laundering and Asset Recovery Section, disbanding its kleptocracy initiative and mandating a focus on a narrower class of cases involving immigration offenses, ties to cartels, transnational criminal organizations, and fentanyl trafficking into the United States.[9] At the same time, the Public Integrity Section, a part of the Criminal Division that handles complex and high-profile investigations of public officials, has seen its staffing reduced to historic lows.[10]

More generally, DOJ has seen vast reductions in its workforce, as a result of deferred resignations,[11] demotions,[12] firings,[13] and other shifts in Departmental priorities.[14] Outside of the Criminal Division, reports indicate that the Department’s Civil Rights Division is facing upwards of a 70% staff reduction.[15] The Department has also begun a complete dismantling of the Civil Division’s Consumer Protection Branch, with further plans to cut National Security Division staff.[16] The net effect of these policy and staffing disruptions may be a reduced role for the Criminal Division and Main Justice more generally, resulting in DOJ’s Washington-based operations looking markedly different compared to prior administrations over the last several decades.

And while Attorney General Bondi has intimated a more corporate-friendly DOJ, any enforcement gaps left by a potentially diminished Main Justice are likely to be filled by the 93 USAOs exercising their independent charging discretion in districts across the country. Indeed, in terms of raw numbers, far more corporate prosecutions are brought by USAOs than by litigating components at Main Justice, even prior to the recently announced policy shifts and structural changes. Unlike USAOs, the Criminal Division has no “home court,” so its prosecutors routinely consult with or affirmatively partner with the USAO in the district with the most appropriate venue over the criminal misconduct. Critically, in the absence of a case-specific partnership between the Criminal Division and a USAO, the CEP does not constrain USAOs’ investigative prerogatives, with each office’s authority limited only by the portions of the Justice Manual that apply to the entirety of DOJ—for example, general considerations for initiating prosecutions of business organizations.[17]

To that end, separate and apart from the CEP, the USAOs maintain their own corporate voluntary self-disclosure policy,[18] with several offices issuing additional district-specific policies focusing on self-disclosures by individuals who have knowledge of and played a role in corporate malfeasance.[19] In practice, this means that USAOs are incentivizing individual whistleblowers to come through their doors and self-report first, which may eliminate a company’s ability to assess how, when, and, critically, to whom it should initiate self-disclosure.

While it is possible these USAO-specific policies may be amended or rescinded in the future, the fact remains that USAOs maintain substantial discretion irrespective of Criminal Division policy. With diminished staffing, as well as the decentralization and dilution of authority at Main Justice, U.S. Attorneys may be poised to enjoy even greater autonomy and flexibility to pursue cases—across the full range of corporate enforcement—that they believe are important based on the specific needs of their respective districts. Depending on the office, these decisions may rest with line Assistant United States Attorneys, adding even greater variability into the process. It is incumbent upon corporations to keep in mind that DOJ is simply not a monolith, and that different parts of the same agency often set and pursue their own policies. As a result, determining where a particular matter may land within DOJ—whether with a USAO, the Criminal Division, or another Main Justice component—and assessing whether and how the relevant office has handled similar cases will be even more critical for companies seeking to avoid surprises and preserve credibility with DOJ in the years to come.

B. Keeping Track of Multijurisdictional Considerations

More broadly, companies considering self-disclosure must also be cognizant of the interplay between DOJ and other federal, state, and foreign enforcement agencies. These agencies often have their own policies and considerations related to self-disclosure and are neither bound by the CEP nor any DOJ policy.  Companies considering self-disclosure to DOJ must therefore consider the multijurisdictional fallout that may result.

Disclosures to DOJ rarely occur in a silo. This is particularly true for heavily regulated companies that have stringent disclosure obligations (e.g., publicly traded companies and financial institutions). Even setting aside a company’s affirmative disclosure obligations, information sharing between regulators is commonplace. Disclosure to DOJ risks triggering parallel or follow-on investigations by, among others, the Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission, the Office of Foreign Assets and Control, state regulators, or foreign enforcement agencies. In fact, corporate resolutions with DOJ often include binding agreements involving multiple domestic regulators, foreign regulators, or some combination of the two. For example, in 2021, Credit Suisse Group AG reached a coordinated global resolution related to misconduct in connection with Credit Suisse’s financing of a tuna fishing project in Mozambique.[20] The resolution included multiple components of DOJ (the Criminal Division’s Money Laundering and Asset Recovery Section and Fraud Section and the USAO for the Eastern District of New York), the SEC, and the UK’s Financial Conduct Authority. Switzerland’s Financial Market Supervisory Authority provided assistance and engaged in its own separate enforcement action against Credit Suisse. Indeed, in his June 10 speech, Galeotti reaffirmed the Criminal Division’s commitment to international cooperation, explaining that when conduct does not directly implicate U.S. interests, “the Criminal Division won’t hesitate to work with our foreign counterparts or domestic regulators to provide assistance and ensure that those countries and regulators can vindicate their interests.”[21] This emphasis reinforces the need for companies to consider multijurisdictional consequences and exposure when evaluating whether, when, and where to self-disclose.

Additionally, in the cross-border context, companies may also face conflicting legal obligations with respect to data protection laws, blocking statutes, and privilege rules. These conflicting legal obligations further complicate the strategic considerations and implications of self-disclosure to DOJ and could negate any potential benefits under the Criminal Division’s updated CEP.

In short, while the revised CEP offers clearer incentives, it does so within a jurisdictionally narrow and operationally fragmented enforcement environment. Companies must navigate not only the limits of the CEP’s formal applicability, as outlined below, but also a global enforcement landscape shaped by shifting priorities, decentralized authority, inconsistent policy adoption, and multijurisdictional exposure. Even the best-prepared disclosure strategy can falter if it fails to account for which federal, state, or foreign agencies have jurisdiction, and those offices’ enforcement history and culture. Yet even for matters clearly within the Criminal Division’s purview, the path to a declination remains far from automatic. As the next section explores, much may turn on how prosecutors interpret one of the policy’s most ambiguous elements: the presence—or absence—of “aggravating circumstances.”

III. “Aggravating Factors” and the Potential Declination Mirage

Putting aside the CEP’s jurisdictional limitations inside and outside DOJ, the updated policy still leaves significant discretion in the hands of Criminal Division prosecutors, and its open ended “aggravating circumstances” provision creates significant uncertainty for companies that voluntarily self-disclose and fully remediate. Even if a company voluntarily self-discloses misconduct to the Criminal Division, prosecutors will consider whether any “aggravating circumstances” weigh against declining to prosecute a company for criminal conduct.

Unlike the Criminal Division’s prior 2023 CEP, which listed specific “aggravating circumstances that may warrant a criminal resolution,” the new CEP gives more general guidelines. Specifically, under the old policy, aggravating circumstances included, but were not limited to: (1) a significant profit to the company from the misconduct, (2) involvement by executive management of the company in the misconduct, (3) the egregiousness or pervasiveness of the misconduct within the company, or (4) criminal recidivism.[22]

For its part, the new CEP jettisons the specific examples of aggravating factors provided in the 2023 CEP, instead stating that the Criminal Division will decline to prosecute a company that fully cooperates and remediates, provided there are no “aggravating circumstances” relating to: (1) the nature and seriousness of the offense; (2) the egregiousness or pervasiveness of the misconduct within the company; (3) the severity of the harm caused by the misconduct; or (4) the recency of another criminal adjudication or resolution based on similar misconduct by the same company (in the last five years). In his June 10 speech, Galeotti emphasized that the revised CEP “narrowed what constitutes an ‘aggravating factor,’ giving even more transparency and certainty for companies deciding whether or not to come forward.”[23] He stated that declinations will be granted, rather than presumed, for companies that voluntarily self-disclose and fully cooperate, absent truly exceptional aggravating circumstances.[24]

These factors, however, still allow for significant discretion by Criminal Division prosecutors, including the discretion to recommend a declination even when aggravating circumstances exist, after weighing the severity of those circumstances against the company’s cooperation and remediation. Even if a company is ineligible for a declination due to aggravating factors, the policy provides that the Criminal Division shall still provide the company with a Non-Prosecution Agreement, absent “particularly egregious or multiple aggravating factors.”[25]

This discretion and the broad nature of “aggravating circumstances” in the new CEP create uncertainty for companies that may believe they qualify for a declination. As a result, companies should prepare for a wide array of scenarios depending on the prosecutor or specific Criminal Division section handling the investigation. That uncertainty is compounded by new pressures around timing and whistleblower incentives, which raise additional strategic concerns addressed in the next section.

IV. Disclosure Timing: Imminent Threats and the Whistleblower Trap

In addition to the potential ambiguity related to the assessment of “aggravating circumstances” under the revised CEP, the policy also adds another layer of complexity by tying a company’s eligibility for a declination to new, time-sensitive whistleblower-related disclosure requirements. In particular, the policy introduces a 120-day deadline for companies—which overlaps with the 120-day deadline for whistleblowers, previously established in the Criminal Division’s Corporate Whistleblower Awards Pilot Program (Pilot Program)—to act following internal reports of potential misconduct. While these changes reflect the Criminal Division’s effort to reward both individual whistleblowers and entities with robust internal compliance systems, they also create practical and strategic pressure points.

The Pilot Program provides financial incentives for whistleblowers to report internally prior to reporting to DOJ. In addition to the significance of the information and the cooperation of the whistleblower, DOJ increases whistleblower awards based on the whistleblower’s participation in the company’s internal compliance and reporting process.[26] Once a whistleblower submits an internal report to the company’s audit committee, chief legal officer, chief compliance officer (or their equivalents), or their supervisor, the whistleblower has 120 days to report the information to DOJ.[27]

In parallel to the 120-day deadline for a whistleblower to report misconduct to DOJ, the new CEP implements a significant adjustment to the Pilot Program relating to a company’s self-disclosure following a whistleblower’s internal report. Specifically, a company can still qualify for a declination under the CEP—even if the whistleblower has gone to the Department before the company self discloses—if the company self-reports the conduct to the Department within 120 days of receiving the internal report and meets the other requirements for voluntary self-disclosure. Critically, one of those requirements is that the company must disclose “prior to an imminent threat of disclosure or government investigation.”[28] The phrase “imminent threat” is not defined in the CEP nor in the U.S. Sentencing Guideline provision it cites.

The benefit of a declination is a powerful reward—but there are several interrelated practical challenges in determining not only whether, but when a company should disclose potential misconduct to DOJ. First, it is exceptionally difficult to determine whether some part of DOJ has already learned of the alleged misconduct, especially in cases involving whistleblowers or parallel agency reviews, such that the “imminent threat” benchmark may prove nearly impossible to meet. Second, companies with decentralized reporting and investigations functions may find it challenging to meet the 120-days-from-receipt deadline to disclose. And, most disconcertingly, in a rush to meet this deadline, companies may ultimately disclose incomplete or inaccurate facts as they truncate a comprehensive investigation in the interest of speed.

Premature self-reporting before completing a comprehensive internal investigation into the alleged misconduct can expose the company to at least two key risks. First, the Criminal Division could determine that the company’s failure to provide a complete and comprehensive report on the alleged misconduct constitutes a failure to “fully cooperate” under the CEP. As a result, rather than receiving a declination or non-prosecution agreement, the company may face criminal prosecution.[29] Second, the Criminal Division could determine that the company’s failure to provide a complete and comprehensive report signals the ineffectiveness of the company’s compliance program and an inability to appropriately detect and remediate future misconduct. While the CEP disfavors the use of monitors, it still considers monitors necessary when a company is unable to “detect and prevent similar misconduct in the future.”[30] To avoid these self-inflicted problems, a company must be confident in its thorough understanding of the alleged misconduct prior to self-disclosure.

These overlapping timelines and undefined thresholds under the revised CEP place companies in a difficult bind—forced to act quickly while ensuring precision and completeness. The expanded CEP may offer greater clarity in some respects, but it also introduces new pressure points that elevate the stakes of internal reporting and investigation. In this environment, companies must be prepared not only to respond swiftly but to do so with confidence in the integrity of their investigative process. And although it is the Criminal Division’s view that “[t]his is the time for companies to self-report,” [31] the cost of missteps in timing, execution, or judgment can be steep, reinforcing that the decision to self-disclose remains one of the most consequential a company can make.

V. Conclusion

The Criminal Division’s revised CEP represents an effort to achieve a more structured and incentive-laden framework for companies willing to disclose misconduct and cooperate with investigations. Its updated pathways to declination, narrowed use of monitors, and thoughtful whistleblower exception reflect the Department’s goal of making enforcement outcomes more predictable.

But predictability is not the same as certainty. The policy only applies to a segment of DOJ, depends on prosecutorial discretion, and requires careful alignment with evolving DOJ policies, parallel enforcement risk, and whistleblower activity.

In short: the CEP creates opportunities—but companies should still proceed with caution. Strategic disclosure is not about being first; it’s about being timely, ready, and realistic.

VI. Practical Takeaways: Strategic Disclosure Requires Strategic Thinking

• Understand DOJ structure. Before disclosing, consider whether the matter is likely to be handled by the Criminal Division (to which the CEP applies) or another part of DOJ (where it does not).

• Consider collateral exposure. Voluntary disclosure to any part of DOJ may trigger (or reveal) parallel actions by other federal, state, and foreign authorities, especially in cross-border matters.

• Calibrate timing carefully. The revised CEP emphasizes prompt disclosure and introduces a whistleblower-related deadline—but definitions like “reasonably prompt” and “imminent threat” remain fact-sensitive.

• Approach disclosure strategically. Don’t assume that simply following the CEP’s decision tree will result in a declination from the Criminal Division. Every element—disclosure, cooperation, and remediation—must be satisfied and supported.

• Plan for prosecutorial discretion. The CEP adds clarity but leaves room for substantial prosecutorial discretion. A company’s view of its own conduct is unlikely to fully align with DOJ’s, regardless of whether the matter is handled by the Criminal Division, another Main Justice component, or a USAO.

[1] Matthew R. Galeotti, Head of the Crim. Div., Head of Justice Department’s Criminal Division Matthew R. Galeotti Delivers Remarks at American Conference Institute Conference (June 10 Speech) (June 10, 2025), https://www.justice.gov/opa/pr/head-justice-departments-criminal-division-matthew-r-galeotti-delivers-remarks-american.

[2] U.S. Dep’t of Just., Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) (2025), https://www.justice.gov/d9/2025-05/revised_corporate_enforcement_policy_-_2025.05.11_-_final_with_flowchart_0.pdf.

[3] June 10 Speech, supra note 1.

[4] U.S. Dep’t of Just., Our Components, https://www.justice.gov/careers/our-components.

[5] U.S. Dep’t of Just., NSD Enforcement Policy for Business Organizations (March 7, 2024), https://www.justice.gov/nsd/media/1285121/dl?inline=; U.S. Dep’t of Just., Antitrust Division Leniency Policy and Procedures (June 2022), https://www.justice.gov/atr/page/file/1490246/dl?inline.

[6] U.S. Dep’t of Just., Factors in Decisions on Criminal Prosecutions (July 1, 1991),https://www.justice.gov/enrd/selected-publications/factors-decisions-criminal-prosecutions.

[7] U.S. Dep’t of Just., Environmental Crimes Section, Environment & Natural Resources Division Voluntary Self-Disclosure Policy (March 2023), https://www.justice.gov/file/1277146/dl?inline=.

[8] Exec. Order No. 14209, 90 Fed. Reg. 9587 (Feb. 10, 2025), https://www.whitehouse.gov/presidential-actions/2025/02/pausing-foreign-corrupt-practices-act-enforcement-to-further-american-economic-and-national-security/; https://www.federalregister.gov/documents/2025/02/14/2025-02736/pausing-foreign-corrupt-practices-act-enforcement-to-further-american-economic-and-national-security.

[9] Office of the Att’y Gen., U.S. Dep’t of Just., Memorandum for all Department Employees (Feb. 5, 2025), https://www.justice.gov/ag/media/1388546/dl?inline.

[10] Perry Stein & Jeremy Roebuck, Trump Justice Department considers removing key check on lawmaker prosecutions, The Wash. Post (May 17, 2025), https://www.washingtonpost.com/national-security/2025/05/17/trump-justice-department-prosecutions/.

[11] Mark Sherman & Will Weissert, Trump offering federal workers buyouts with about 8 months’ pay in effort to shrink government, AP News (Jan. 28, 2025), https://apnews.com/article/trump-buyouts-to-all-federal-employees-f67f5751a0fd5ad8471806a5a1067b5e.

[12] Sarah N. Lynch, US Justice Department senior career ethics official removed from post, source says, Reuters (Jan. 27, 2025),https://www.reuters.com/world/us/us-justice-department-senior-career-ethics-official-removed-post-source-says-2025-01-27/.

[13] Perry Stein & Ellen Nakashima, Justice Dept. removes senior career officials from key positions, The Wash. Post (Jan. 21, 2025), https://www.washingtonpost.com/national-security/2025/01/21/justice-trump-removes-senior-staffers-national-security-criminal/.

[14] Ryan Lucas, 70% of the DOJ’s Civil Rights Division Lawyers are leaving because of Trump’s reshaping, NPR (May 19, 2025), https://www.npr.org/2025/05/19/g-s1-66906/trump-civil-rights-justice-exodus; William K. Rashbaum, Benjamin Weiser, Jonah E. Bromwich, & Maggie Haberman, Order to Drop Adams Case Prompts Resignations in New York and Washington, N.Y. Times (Feb. 13, 2025), https://www.nytimes.com/2025/02/13/nyregion/danielle-sassoon-quit-eric-adams.html.

[15] Lucas, supra note 13.

[16] Sarah N. Lynch, US Justice Department unit for drug and food safety cases being disbanded, Reuters (Apr. 25, 2025), https://www.reuters.com/business/healthcare-pharmaceuticals/us-justice-department-unit-drug-food-safety-cases-being-disbanded-2025-04-25/; Sarah N. Lynch, US Justice Department considers merging DEA, ATF in major shakeup, memo says, Reuters (Mar. 27, 2025), https://www.reuters.com/world/us/us-justice-department-considers-merging-dea-atf-major-wave-cuts-memo-shows-2025-03-27/.

[17] U.S. Dep’t of Just., Justice Manual (JM) § 9-28.00 – Principles of Federal Prosecution of Business Organizations, https://www.justice.gov/jm/jm-9-28000-principles-federal-prosecution-business-organizations.

[18] U.S. Dep’t of Just., United States Attorneys’ Offices Voluntary Self-Disclosure Policy (2024), https://www.justice.gov/d9/pages/attachments/2023/02/23/usao_voluntary_self-disclosure_policy.pdf.

[19] See, e.g., E.D.N.Y. Whistleblower Non-Prosecution Pilot Program (2024), https://www.justice.gov/usao-edny/media/1368306/dl?inline.

[20] U.S. Dep’t of Just., Press Release, Credit Suisse Resolves Fraudulent Mozambique Loan Case in $547 Million Coordinated Global Resolution (Oct. 19, 2021), https://www.justice.gov/archives/opa/pr/credit-suisse-resolves-fraudulent-mozambique-loan-case-547-million-coordinated-global.

[21] June 10 Speech, supra note 1.

[22] U.S. Dep’t of Just., Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy (2023), https://www.justice.gov/criminal/criminal-fraud/file/1562831/dl?inline.

[23] June 10 Speech, supra note 11.

[24] Id.

[25] CEP, supra note 2.

[26] U.S. Dep’t of Just., Department of Justice Corporate Whistleblower Awards Pilot Program 10–11 (May 12, 2025), chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.justice.gov/criminal/media/1400041/dl?inline.

[27] Id. at 4.

[28] Id. (citing U.S.S.G. § 8C2.5(g)(1)).

[29] CEP, supra note 2.

[30] Matthew R. Galeotti, Head of the Crim. Div., Memorandum on Selection of Monitors in Criminal Division Matters to all Crim. Div. Personnel 3 (May 12, 2025), https://www.justice.gov/criminal/media/1400036/dl?inline.

[31] June 10 Speech, supra note 1.