According to Lawfare here, AG Pam Bondi issued several new guidance memos today. Several relate to white collar crime – This is a discussion of the one on Third Party Payments - 

Third Party Settlements – "Settlements, including civil settlement agreements, deferred prosecution agreements, non-prosecution agreements, and plea agreements, are a useful tool for Department attorneys, and should be used, first and foremost, to compensate victims, redress harm, or punish and deter unlawful conduct. Except in limited circumstances, however, settlements should not be used to require payments to non-governmental, third-party organizations that were neither victims nor parties to the lawsuits."

Former AG Jeff Sessions had also placed limits on third party settlements.  AG Bondi says "no" to the settlements to third parties, but leaves open their use if it fits within victims compensation and deterence. This is similar to the Sessions' Memo, but has some distinctions.  Perhaps the most noticeable distinctions are that: a) she "rescind[s] the May 5, 2022 Memorandum from the Attorney General [Garland] entitled Guidelines and Limitations for Settlement Agreements Involving Payments to Non Governmental Third Parties and the July 28, 2023 Memorandum from the Assistant Attorney General for the Environmental and Natural Resources Division entitled Community Service Payments in Environmental Crimes Cases;" and b) She wants to go back and look at existing ones ("Moreover, I am directing the Associate Attorney General to provide a report to me within 30 days concerning strategies and measures that can be utilized to eliminate the illegal or improper use memoranda to direct payments to non-governmental, third-party organizations that were neither victims nor parties to the lawsuits.").  This last part is particularly interesting – Will contracts in good faith with the government be subject to scrutiny? 

Note the Memo Under AG William Barr here and the Memo under AG Jeff Sessions here. 

Bondi's other Memos of today can be found here. 

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