Economy February 5, 2026

Manhattan U.S. Attorney Seeks Fast Non-Prosecution Deals to Reward Corporate Cooperation

Jay Clayton says prosecutors will offer NPAs to companies that assist criminal investigations as Justice Department shifts enforcement priorities

By Priya Menon
Manhattan U.S. Attorney Seeks Fast Non-Prosecution Deals to Reward Corporate Cooperation

The U.S. Attorney in Manhattan announced plans to expand incentives for corporate cooperation in criminal probes, including quick non-prosecution agreements (NPAs). Speaking at a securities enforcement forum in New York, he framed the approach as a way to encourage cooperation, protect shareholders and target misconduct in small-cap stocks, private funds and prediction markets. He also criticized how the Foreign Corrupt Practices Act has been applied and noted recent changes in its enforcement.

Key Points

  • Manhattan U.S. Attorney Jay Clayton said prosecutors will increase incentives for corporate cooperation, including offering non-prosecution agreements (NPAs).
  • The Justice Department is scaling back corporate crime enforcement and refocusing resources on immigration and drug cases under the Trump administration; Clayton said the cooperation-focused approach would also benefit shareholders.
  • Clayton identified small-cap stocks, private funds and prediction markets as areas of concern and affirmed prosecutors could pursue cases tied to event contracts.

Federal prosecutors intend to increase the rewards offered to companies that help criminal investigations, including assurances they will not be prosecuted if they cooperate, the U.S. Attorney in Manhattan said on Thursday.

Jay Clayton made the remarks at the Securities Enforcement Forum in New York, laying out a strategy that places greater emphasis on negotiating non-prosecution agreements - commonly called NPAs - with corporate actors that provide sustained cooperation. He framed the approach as a concrete benefit designed to encourage companies to assist prosecutors in identifying wrongdoers.

"Our approach is going to be: let’s get an NPA signed as quickly as possible that calls for continued cooperation," Clayton said at the conference.

The comments come as the Justice Department has been pulling back on corporate crime enforcement and shifting resources toward immigration and drug cases under the Trump administration. Clayton said the revised focus on cooperation and the use of NPAs would also serve shareholder interests.

Clayton, an appointee of President Donald Trump, previously led the Securities and Exchange Commission during the administration's first term. During his time at the SEC he placed emphasis on protections for retail investors, and he indicated those investors remain a central concern for him in his current role prosecuting white-collar crime.

He said prosecutors are watching for misconduct in areas he listed as priorities: small-cap stocks, private funds and prediction markets. When asked whether prosecutions are likely in event contracts - sometimes called event contracts or prediction-market style instruments - he responded, "Yes."

Clayton also leveled criticism at how the Foreign Corrupt Practices Act has been enforced. He noted that the Justice Department suspended enforcement of the law last year and later resumed it under a more limited framework. He argued the law, as applied historically, disadvantaged U.S. companies relative to foreign competitors and tended to punish corporate entities rather than the individuals who commit wrongdoing.

"I hate corruption of foreign officials," he said. "I hate the FCPA as applied."


Context and implications

Clayton presented the NPA-focused approach as a practical tool to extract cooperation from corporations and to realign prosecutorial resources. He emphasized shareholder protection as part of his enforcement priorities while signaling attention to specific market segments where he sees potential misconduct.

The remarks reflect a broader departmental shift in enforcement emphasis and a debate about how best to hold wrongdoers to account while preserving competitive standing for U.S. firms.

Risks

  • Political and legal pushback - NPAs have attracted criticism from Democrats in the past, suggesting potential political contention around broader use of such agreements; this could affect enforcement policy and corporate legal strategies.
  • Enforcement uncertainty under FCPA changes - the Justice Department paused then resumed enforcement of the Foreign Corrupt Practices Act with a scaled-back approach, raising questions about how corruption cases will be pursued and whether individuals or companies will be the primary targets.
  • Shifts in enforcement priorities - the move to reduce corporate crime emphasis while increasing focus on immigration and drug cases introduces uncertainty for companies and markets that previously expected more aggressive corporate prosecutions; corporate, legal and financial sectors could be affected.

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