News & Analysis as of

Civil Monetary Penalty Mitigation

Husch Blackwell LLP

CFTC Enforcement Division Releases Mitigation Credit Matrix for Self-Reporting, Cooperation, and Remediation

Husch Blackwell LLP on

On February 25, 2025, the Commodity Futures Trading Commission (CFTC) signaled a shift in its enforcement approach by releasing new guidance on the role self-reporting and cooperation play in its assessment of penalties. The...more

Baker Botts L.L.P.

CFTC Issues Enforcement Advisory Adopting New Approach for Consideration of Self-Reporting, Cooperation, and Remediation

Baker Botts L.L.P. on

On February 25th, the Commodity Futures Trading Commission (CFTC or Commission) adopted a new approach for how the Division of Enforcement (Division) will assess self-reporting, cooperation, and remediation efforts when...more

Venable LLP

CFIUS Proposes Increased Penalties for Noncompliance and Updated Mitigation and Enforcement Rules

Venable LLP on

As the lead agency for the Committee on Foreign Investment in the United States (CFIUS or the Committee), the U.S. Department of the Treasury released new proposed rules on April 11, 2024 intended to enhance the enforcement...more

White & Case LLP

CFIUS Proposes Regulatory Updates to Shorten Mitigation Negotiation Timelines for Transaction Parties & Expand CFIUS Authorities...

White & Case LLP on

On April 11th, the US Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (CFIUS), issued a Notice of Proposed Rulemaking (NPRM) to "enhance certain CFIUS procedures and sharpen...more

Sheppard Mullin Richter & Hampton LLP

FTC, Florida Settle with Chargeback Mitigation Company for $150K

On November 7, the FTC and the State of Florida settled with a chargeback mitigation company and its owners for $150,000. The chargeback company was allegedly using deceptive practices, including referencing disclaimers that...more

McCarter & English, LLP

CFIUS Issues Enforcement and Penalty Guidelines: A Contextual View

Although announced two years earlier, Enforcement and Penalty Guidelines (the Guidelines) were finally released by the US Department of the Treasury (Treasury) as Chair of the Committee on Foreign Investment in the United...more

(ACOEL) | American College of Environmental...

Should Someone be Reading The SEP Policy its Last Rights?

Chances are if you have been on either side of a settlement for an environmental violation over the past 20 years, you have discussed and/or negotiated a supplemental environmental project (SEP) as part of the overall...more

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

Volkswagen Settlement/Arkansas Mitigation Plan: Stuart Spencer (Arkansas Department of Environmental Quality) Arkansas Bar...

Stuart Spencer of the Arkansas Department of Environmental Quality (“ADEQ”) undertook a presentation at the March meeting of the Arkansas Bar Association Environmental Law Section titled: Volkswagen Settlement –...more

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