Revolving Door Project Launches Corporate Crime Enforcement Capacity Tracker

A new Revolving Door Project tracker records cuts made by the Trump administration to enforcement capacity at agencies responsible for overseeing corporations’ activities and identifying wrongdoing. 

Emma Marsano

Enforcement capacity refers to staffing and funding dedicated to monitoring, oversight, investigation, and preparation of cases against corporations for breaking the law. Cuts to and attacks on enforcement capacity can include firings, buyout offers, funding cuts, reorganizations, and other similar steps the Trump administration has taken to date.

Currently, the tracker features fourteen agencies including the Department of Justice, Internal Revenue Service, Consumer Financial Protection Bureau, and Department of Health and Human Services.

Each entry features an overview of the enforcement function of the agency, an analysis of who will be hurt by these cuts and who stands to benefit, links to further resources on the Trump administration’s impact on the agency, and a chronological list of developments limiting the agency’s enforcement capacity since the start of Trump’s second term 

“The Trump administration has slashed the capacity of federal agencies across the board, but they have focused with particular ardor on the agencies that investigate and prepare enforcement cases against law-breaking corporations,” said Revolving Door Project researcher Emma Marsano. “These cuts amount to an open license for corporations to exploit people and the planet as they mercilessly pursue profit above all.” 

“This tracker gives a detailed look at the Trump administration’s targeted attacks on white-collar crime enforcement powers of the federal government and their predicted impact,” said the group’s executive director Jeff Hauser. “We’ve argued for years that these enforcement powers are under-utilized, and were critical of the Biden administration’s already lax approach to corporate crime. Now, we’re seeing the rapid acceleration of what has been a bipartisan failure to enforce the law against corporations and the wealthy more broadly – and the harms that stand to affect all of us, particularly those already most vulnerable, are striking.” 

What was the genesis of this project?

“We have been in a tracker mode – tracking everything from aviation disasters to non compliance with court orders,” Marsano told Corporate Crime Reporter in an interview last week.

“This tracker came out of conversations with our team. It tracks enforcement and investigations. These are the people who are doing the work to create a pipeline of corporate crime enforcement cases.” 

“The tracker is designed to work in concert with the tracker put out by Public Citizen. That tracker looks at actual enforcement cases that are being dropped or reversed. You can go in and see a specific case that had been dropped by the Department of Justice or otherwise halted.” 

“Our tracker looks at the damage done to the federal enforcement infrastructure that generates a pool of cases moving forward.”

You cover most of the major enforcement agencies. There was a wholesale attack on the Consumer Financial Protection Bureau (CFPB), while the attack on the SEC was not as frontal – it was more like death by a thousand cuts. They offered early retirement to SEC staff. I think they are down by fifteen percent in staff.

“I imagine that the different approaches have to do with politics,” Marsano said. “The administration is looking at which dismantling of agencies will have greater or lesser public support.”

The SEC has a longer historic record of law enforcement. And they might be more untouchable because they have a larger alumni corps that are spread evenly throughout the corporate defense bar.

What do we know about the dismantling of the Department of Justice?

“There have been a number of announcements out of the Department of Justice. Initially Pam Bondi announced the scaling back of enforcement of laws governing bribing of foreign officials. She specifically disbanded the National Security Division’s corporate enforcement unit and reassigned the attorneys who had been working in that unit.”

“They have redirected enforcement to immigration and public safety concerns. Sometimes implicitly, sometimes explicitly, they talk about how they are reassigning staff so that prosecutors will be less able to focus on white collar crime, civil fraud and civil rights investigations to the same extent as before.”

“It’s been largely a combination of shutting down certain units and reassigning prosecutors who were working on corporate crime investigations and prosecutions. They have also issued some policy announcements. Last month they released a new corporate enforcement policy that is a classic rhetorical mess. It claims to points out ten categories of white collar crime that it claims it will focus on enforcing, but actually when you read between the lines it offers a clear pathway for corporations to self-report wrongdoing and cooperate, complete with a literal flow chart diagram with all of the ways that corporations can use self-disclosures to avoid prosecution.”

“In announcing this new policy, the head of the Department’s Criminal Division spoke about corporate enforcement as something that had been “coming at too high a cost for business and American enterprise” but offering no evidence to support that claim.”

“That was a signal to corporations that it is open season to do whatever they want, break the law and get away with it as long as at some point they admit that to the Department.”

They are employing the rhetoric that all administrations do – that white collar crime remains a focus of the Department.

The Wall Street Journal reported this week that “the Justice Department will resume investigating foreign-bribery cases with a narrowed focus on matters that relate to U.S. strategic interests, including buttressing the ability of American firms to compete for business overseas.”

“Deputy Attorney General Todd Blanche announced the changes after a four-month review triggered by President Trump’s order earlier this year freezing corruption investigations. Trump said at the time that enforcement of a federal anti bribery law, the Foreign Corrupt Practices Act, puts American firms at a disadvantage to foreign rivals that can engage in conduct forbidden in the U.S.”

“The department has closed nearly half of its foreign-bribery investigations to align with new guidelines Blanche issued Tuesday, according to senior Justice Department officials.”

“This Justice Department has overhauled FCPA enforcement to protect American businesses and sharpen our national security focus,” Blanche wrote Tuesday on X. “We’re ending abusive overreach and closing cases that never should’ve been opened.”

Did you see that Journal article?

“Yes, and in that article, the Journal reports that only 25 individuals are going to be involved in the FCPA cases in work going forward.”

OK, I see that. The Journal reports – “The number of prosecutors assigned to work exclusively on foreign-corruption matters has fallen during the Trump administration. About 25 will be involved in the work going forward, according to officials.”

But they don’t report how many Department lawyers were working those cases before this administration came into office. So it is 25 now, but what was it before, do we know?

“We don’t, although we are expanding our project to look at how many full time employees across these agencies were working on these issues before this administration came into office.”

Is it your sense that across the board there was a 15 percent cut?

“Some agencies are losing a bigger chunk than that. The gutting of the IRS and CFPB has been more devastating. But the targeting of enforcement capacity has been consistent across the board.”

“The attack on the CFPB has been more high-profile. They have cut over 1,500 employees. It has been one of the more shameless and one of the most blatant examples of the Trump administration’s effort to prevent corporations from being held accountable. They have closed offices, fired people, and fought off court orders to reinstate employees. They cut 200 out of 250 members of the CFPB’s enforcement division. It’s absolutely clear that they are trying to destroy the agency.” 

Only a handful of public interest groups in Washington have projects on corporate crime are Public Citizen and the Revolving Door Project. Do you know of any others?

“Yes, Good Jobs First reached out to us. They maintain a Violations Tracker. We are looking to collaborate. Some of the other groups do issue area work that overlaps with our work. We have fourteen agencies in our tracker, the ones with the most influential and relevant enforcement roles. But there are more that we could get into as well.” 

“There are environmental groups for example that track what’s happening at the EPA. And I cite much of their work.” 

Very few members of Congress use the term corporate crime. But it seems like a populist issue. Why hasn’t it broken through politically?

“It’s hard not to think of corporate sponsored media and the corporate powers that shape our mainstream discourse and the reasons people would shy away from the ways corporations are flouting the law and getting away with it.”

[For the complete q/a format Interview with Emma Marsano, see 39 Corporate Crime Reporter 24(14), June 9, 2025, print edition only.]

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