On August 13, 2026, Assistant Attorney General Colin M. McDonald issued the first enforcement priorities memorandum for the Department of Justice’s (DOJ) new National Fraud Enforcement Division (Fraud Division).1 The memorandum establishes five priority enforcement areas for what the DOJ describes as the first division in Department history dedicated solely to detecting, investigating, and prosecuting fraud against the United States and its citizens. With an estimated $233 to $521 billion in annual federal fraud losses at stake, the Division represents a fundamental restructuring of how the federal government pursues fraud—and companies across industries should take notice.
This alert discusses:
- The DOJ’s announcement and the Fraud Division’s structure;
- The five stated enforcement priority areas;
- Why this matters for companies, government contractors, and regulated entities; and
- Key…
PROCUREMENT & EXPENDITURE (STOPPING KICKBACKS)
Procurement fraud usually involves inflated invoices or “fictitious” vendors.
- The Three-Way Match: Never pay an invoice unless you have matched the Purchase Order (PO), the Delivery Note (signed), and the Supplier Invoice.
- Vendor Master File Review: Review your vendor list annually. Look for suppliers with the same bank details or physical addresses as your employees.
- Dual Authorization: Implement a “Two-to-Sign” rule for all EFT payments above a certain threshold (e.g., R5,000).
- No “Cashing” of Checks: If you still use physical checks, strictly prohibit “Cash” as a payee and store blank checks in a dual-lock safe.