The U.S. Attorney’s Office for the Eastern District of Pennsylvania (the “EDPA”) announced the implementation of its White-Collar Justice Program in September 2025, a move that reaffirmed the office’s public commitment to white collar enforcement under newly appointed U.S. Attorney David Metcalf. The new U.S. Attorney has made clear that white collar enforcement is going to be a major focus of the office under his leadership, and he is committed to aggressively pursuing investigations and prosecutions involving healthcare, securities fraud, public corruption, and other traditional white collar criminal violations in the EDPA.

Corporate Transparency Initiative 

A cornerstone of the EDPA’s White-Collar Justice Program is the Voluntary Self-Disclosure (“VSD”) Program. An expansion of an existing Department of Justice (“DOJ”) program, it allows companies that discover illegal activity the opportunity to disclose it in exchange for certain benefits. The program has two tiers: the first tier (which requires disclosure before detection, full investigative cooperation, timely and appropriate remediation, and the absence of any aggravating factors) allows a company to avoid prosecution entirely, while the second tier allows for reduced penalties and potential exemption from monitorship.

Metcalf, who was corporate counsel for Amazon before his appointment, is sympathetic to company concerns about self-reporting to the DOJ. With that in mind, the VSD Program seeks to provide concrete incentives to corporate clients and their counsel who report issues as early as possible after discovery of a potential violation. Corporations and their counsel are encouraged to contact the EDPA unit supervisors directly, and to test the waters by presenting “hypothetical conversations” at an early stage.

Enforcement Priorities: Healthcare, Securities, and Public Corruption

In addition to the VSD Program, the U.S. Attorney's Office is actively seeking to tackle investigations and enforcement matters that involve healthcare companies and providers, Fortune 500 public companies, and financial institutions, given the number and size of those entities with operations in the EDPA.   

Healthcare Fraud

The EDPA is a major hub for the healthcare industry, and it handles a significant qui tam/False Claims Act (“FCA”) docket. Metcalf has emphasized that he intends the EDPA to be a leader in healthcare fraud enforcement. Concrete steps his office is taking include:

• Reconstituting DOJ’s Health Care Fraud Strike Force model in Philadelphia, including embedding trial attorneys from Main Justice in the EDPA, hiring additional prosecutors, and assigning the top Assistant U.S. Attorneys (“AUSAs”) in the district to work on healthcare fraud matters.
• Leveraging the office’s qui tam/FCA docket via the Government Fraud Alliance, in which civil and criminal AUSAs work together from the inception of a civil FCA filing to determine whether there is a basis to pursue a criminal case as well.
• Renewing the office’s commitment to promptly and aggressively investigate potential criminal conduct along with the civil qui tam investigation. These efforts will take place under new leadership and increased staffing in the FCA Qui Tam Program.

Companies in the healthcare sector should prepare for an increase in investigations, as the EDPA seeks to encourage internal whistleblowers to file FCA cases in the district. 

Investor and Securities Fraud

The EDPA is increasing its focus on source cultivation as a means of generating cases. With respect to securities fraud matters, this includes:

• Reviewing open-source material and the civil litigation docket in the EDPA federal courts. AUSAs are instructed to immerse themselves in the news and developments emerging from Wall Street and the financial system and to act without hesitation if they see a basis for criminal investigation.
• Actively partnering with financial regulators at the local and national level, as well as taking on cases that the Securities and Exchange Commission may have developed in a different office or region.
• Engaging with the legal and business communities both within and outside the district.

Public Corruption 

The EDPA has traditionally been known for its public corruption prosecutions, and the current U.S. Attorney has pledged to uphold that tradition. Metcalf emphasizes the need for his office to establish relationships and maintain dialogues such that individuals who know or learn about offense conduct feel comfortable reporting it.  

Looking Beyond the Eastern District 

Metcalf has made clear that, in addition to local matters and offenses, he would like his office to compete for nationally significant white collar matters with ties to the EDPA. Metcalf seeks to revamp the office’s culture around case origination, encouraging AUSAs to proactively and aggressively seek out new matters. That cultural transformation will be effectuated through the office’s structure, its hiring strategy, and the policies and programs that it implements. 

Key Takeaways for Corporate Clients 

• The EDPA is sharpening its focus on white collar enforcement, and in particular on healthcare fraud, securities fraud, and public corruption.
• The Voluntary Self-Disclosure Program is a key part of Metcalf’s agenda and may offer a potential route to corporate clients in certain situations that are looking to avoid prosecution, high penalties, and burdensome monitoring.
• The U.S. Attorney’s Office in the EDPA is committed to traditional white collar enforcement and plans to pursue it aggressively.

More details about the White-Collar Justice Program, including the Voluntary Self-Disclosure Program, can be found here: Eastern District of Pennsylvania | White-Collar Justice Program