News & Analysis as of

Civil Monetary Penalty Enforcement Actions

Ballard Spahr LLP

CFPB files complaint against Synapse Financial Technologies

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The CFPB has filed a complaint against Synapse Financial Technologies Inc, alleging that the company engaged in unfair acts and practices in violation of the Section 1036(a)(1)(B) of the CFPA by failing to maintain sufficient...more

Mitchell, Williams, Selig, Gates & Woodyard,...

112(r)/Air Enforcement: U.S. Environmental Protection Agency and City of Dallas, Oregon Wastewater Treatment Plant Enter into...

The United States Environmental Protection Agency (“EPA”) and City of Dallas, Oregon entered into a July 25th Expedited Settlement Agreement (“ESA”) addressing an alleged violation of the Clean Air Act. See DOCKET NO....more

Troutman Pepper Locke

SEC Charges TZP Management Associates With Breaching Fiduciary Duty by Overcharging Management Fees to Private Funds

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Last week, TZP Management Associates, LLC (TZP), a New York-based private equity investment adviser, agreed to pay more than $680,000 in monetary relief to settle charges brought by the Securities and Exchange Commission...more

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Air Enforcement: Tennessee Air Pollution Control Board Proposed Order Addressing Morristown Resin Pellet Manufacturing Facility

The Tennessee Air Pollution Control Board (“Board”) issued a July 31st Technical Secretary’s Order and Assessment of Civil Penalty (“Order”) to Colortech, Inc. (“CI”) addressing an alleged violation of an Air Permit. See Case...more

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Transportation/Used Oil Enforcement: Alabama Department of Environmental Management and Montgomery Waste Transportation Company...

The Alabama Department of Environmental Management (“ADEM”) and Sun Coast Resources, LLC (“SCR”) entered into an August 7th Consent Order (“CO”) addressing the violation of certain Alabama regulations concerning...more

McGuireWoods LLP

State AGs Step Up Enforcement: Recent Lessons from Privacy Law Enforcement in Connecticut and Nebraska

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In 2020, California was the first mover in state comprehensive privacy law legislation, a distinction it held for approximately three years before other states took similar action. Indeed, eighteen additional states have...more

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Hazardous Waste Enforcement: Mississippi Commission on Environmental Quality and Hernando Automotive Products Formulator Enter...

The Mississippi Commission on Environmental Quality (“MCEQ”) and Niteo Products LLC (“NP”) entered into a June 17th Agreed Order (“AO”) addressing alleged violations of the Mississippi Hazardous Waste Regulations. See Order...more

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Hazardous Waste Enforcement: Alabama Department of Environmental Management and Brewton Railcar Repair Facility Enter into Consent...

The Alabama Department of Environmental Management (“ADEM”) and Frit Car, Inc. (“FCI”) entered into an August 6th Consent Order (“CO”) addressing alleged violations of the Alabama Hazardous Waste Regulations. See Consent...more

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U.S. Environmental Protection Agency Complaint/Notice of Opportunity for Hearing Addressing Kapolei, Hawaii Waste Recycling...

The United States Environmental Protection Agency (“EPA”) filed a Complaint and Notice of Opportunity for Hearing (“Complaint”) against Unitek Solvent Services, Inc. (“Unitek”) on August 6th alleging violations of the Hawaii...more

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Air Enforcement: Tennessee Air Pollution Control Board Proposed Order Addressing South Pittsburg Iron Foundry

The Tennessee Air Pollution Control Board (“Board”) issued a July 31st Proposed Technical Secretary’s Order and Assessment of Civil Penalty (“Order”) to Lodge Manufacturing Company (“Lodge”) addressing alleged violations of a...more

Allen Matkins

California Environmental Law & Policy Update 8.8.25

Allen Matkins on

On July 23, 2025, the White House issued an Executive Order titled “Accelerating Federal Permitting of Data Center Infrastructure.” Released alongside “America’s Artificial Intelligence (AI) Action Plan,” the Order reflects a...more

Troutman Pepper Locke

FDA Tobacco Civil Money Penalty Provisions Ruled Unconstitutional, but Not Enjoined Nationwide

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In early August, the U.S. District Court for the Northern District of Texas ruled that the civil money penalty (CMP) provision in the Food, Drug, and Cosmetic Act (FDCA) for tobacco products, 21 U.S.C. § 333(f)(9), is...more

Barnea Jaffa Lande & Co.

European Commission Tightens Law Enforcement on Pharmaceutical Cartels

In July 2025, the European Competition Commission imposed a EUR 489,000 fine on Alchem International Pvt. Ltd. and its Hong Kong subsidiary for their involvement in a pharmaceutical cartel involving the active ingredient used...more

Parker Poe Adams & Bernstein LLP

Is FDA's Civil Money Penalty Authority Dead, and If So, What Does It Mean for Life Sciences Companies?

Does the recent decision in a federal district court in Texas, finding that the U.S. Food and Drug Administration’s tobacco civil money penalty authority is unconstitutional, mean the end of the federal agency bringing...more

Venable LLP

The Administrative False Claims Act: 10 Fast Facts That Matter

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The Administrative False Claims Act (AFCA), enacted in December 2024, expands agency authority and recovery limits, making the AFCA a more powerful tool for recouping government funds lost to alleged false claims—a...more

Orrick, Herrington & Sutcliffe LLP

CFPB terminates its consent order with a credit union

On July 18, the CFPB terminated a consent order against a credit union after confirming that the credit union fulfilled “certain obligations” under the original consent order, including paying a $1.5 million civil money...more

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Air Enforcement: Mississippi Commission on Environmental Quality and Grenada County Lumber Company Enter into Agreed Order

The Mississippi Commission on Environmental Quality (“MCEQ”) and Hankins Lumber Company Inc. (“Hankins”) entered into an April 30th Agreed Order (“AO”) addressing alleged violations of a Title V Operating Permit. See Order...more

Fisher Phillips

Farm Employers Score Major Win in H-2A Dispute – How Your Business Should Respond to Federal Appeals Court Decision

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A federal appeals court just ruled that the Department of Labor’s administrative system for imposing civil penalties on agricultural employers for H-2A violations is unconstitutional, handing businesses across all industries...more

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Underground Injection Control Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“DEQ”) and the Hounds’ Hideaway Rogers, LLC (“Hounds”) entered into an April 9th Consent Administrative Order (“CAO”) addressing an...more

Ropes & Gray LLP

[Podcast] Patient Assistance Programs: Enforcement Trends and Regulatory Challenges

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On this Ropes & Gray podcast, health care partner Michael Lampert and counsel Sam Perrone, and litigation & enforcement partner Andrew O’Connor, rejoin to discuss patient assistance programs, recent enforcement actions, and...more

Goodwin

CFPB Terminates Consent Order Against Credit Union

Goodwin on

On July 21, 2025, the Consumer Financial Protection Bureau (CFPB) announced that it had terminated its October 2024 consent order with a Florida-based credit union....more

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Clean Water Act: U.S. Environmental Protection Agency and Reno, Nevada Master-Planned Community Development Enter into Consent...

The United States Environmental Protection Agency (“EPA”) and Nevada Tri Partners, LLC (“NTP”), and Damonte Ranch Commerce Center, LLC (“Damonte”) entered into a July 1st Consent Agreement and Final Order (“CAFO”) addressing...more

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Air Enforcement: Mississippi Commission on Environmental Quality and Greenwood Soybean Processing/Oil Extraction Facility Enter...

The Mississippi Commission on Environmental Quality (“MCEQ”) and Oxbow Greenwood, LLC (“OG”) entered into a July 3rd Agreed Order 9 (“AO”) addressing alleged violations of an Air Permit. See Order No. 7520 25....more

WilmerHale

2024 CMS Audit and Enforcement Report

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On July 15, 2025, the Centers for Medicare & Medicaid Services (CMS) released an Audit and Enforcement Report summarizing its annual Medicare Advantage (Part C) and Prescription Drug (Part D) program audits and enforcement...more

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112(r)/Air Enforcement: U.S. Environmental Protection Agency and Santa Ana, California Chemical Supplier Enter into Expedited...

The United States Environmental Protection Agency (“EPA”) and Gallade Chemical, Inc. (“GCI”) entered into a July 11th Expedited Settlement Agreement (“ESA”) addressing alleged violations of the regulations implementing...more

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