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Corporate Counsel Enforcement Actions

Wiley Rein LLP

CFIUS 2024 Annual Report: Compliance, Enforcement, and Non‑Notified Transactions – What Dealmakers Need to Know

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The Committee on Foreign Investment in the United States (CFIUS) recently released the public version of its Annual Report to Congress for calendar year 2024. Key trends include an increase in formal inquiries into...more

Morrison & Foerster LLP

Algorithmic “Collusion” Theories: Check Out Time or Extended Stay? Ninth Circuit Affirms Complaint Dismissal As Algorithm Scrutiny...

On August 15, 2025, the Ninth Circuit affirmed dismissal of a putative class action alleging Las Vegas Strip hotels used Cendyn Group’s revenue management software to artificially inflate prices in violation of Section 1 of...more

WilmerHale

DOJ Health Care Fraud Unit Announces First Enforcement Action Under Updated Corporate Enforcement Policy

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The U.S. Department of Justice (“DOJ”) Criminal Division and the U.S. Attorney’s Office for the Western District of North Carolina recently announced the first non-prosecution agreement (“NPA”) coming out of DOJ’s Health Care...more

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for July 2025

Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine the following matters: • An SEC complaint alleging a Georgia...more

Troutman Pepper Locke

AGs Demand End to Unlawful Robocalls Through “Operation Robocall Roundup”

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In 2022, a bipartisan task force of 51 state attorneys general (AGs) was formed to investigate and take legal action against companies allegedly responsible for large volumes of fraudulent and illegal robocall traffic. North...more

Pillsbury Winthrop Shaw Pittman LLP

NYDFS Imposes $2M Penalty for Violations of its Cybersecurity Regulation

The New York State Department of Financial Services (NYDFS) announced on August 14, 2025, resolution of civil enforcement action requiring Healthplex, Inc., a licensed insurance agent and independent adjuster, to pay a $2...more

Paul Hastings LLP

You’ve Got Mail: NYDFS Enforcement Action Highlights Cybersecurity Risk of Over-Retention and Other Risks

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On Aug. 14, 2025, the New York Department of Financial Services (NYDFS) issued a Consent Decree announcing that Healthplex, Inc. (Healthplex) has agreed to pay a $2 million fine, as a result of an investigation into a 2021...more

Brownstein Hyatt Farber Schreck

Emerging Counterfeiting Tactic: Private Label Marks to Evade Online Enforcement

A new and increasingly sophisticated form of counterfeiting is challenging traditional brand protection strategies. Counterfeiters are now avoiding the use of well-known house marks and instead applying “private label” marks...more

DLA Piper

CFIUS 2024 Annual Report: Key Trends, Enforcement, and Considerations for 2025

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The Committee on Foreign Investment in the United States (CFIUS) released its 2024 Annual Report to Congress on August 6, 2025, outlining key trends in filings for the 2024 calendar year....more

Parker Poe Adams & Bernstein LLP

OSHA Changes Penalty and Collection Policies

Last month, the federal Occupational Safety and Health Administration issued updated guidance on penalty and debt collection procedures. According to OSHA, the policy revisions are intended to assist small businesses with...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Pay Transparency Update: Summer 2025

As employers move into the second half of 2025, pay transparency continues to expand across the states. And, perhaps, enforcement is starting to keep pace with legislative activity....more

Womble Bond Dickinson

Can a Whistleblower Derail a Deferred Prosecution Agreement?

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A recent whistleblower suit could impact a company’s deferred prosecution agreement (“DPA”) potentially leading to further investigation by DOJ and additional penalties. A whistleblower suit was recently filed in the New...more

Loeb & Loeb LLP

Match Group’s $14 Million Lesson: Even Without “Click-to-Cancel,” Subscription Companies Can’t Play Hard to Get

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Last week, Match Group Inc., the powerhouse behind Match.com, OkCupid, Plenty of Fish and The League, agreed to shell out $14 million and revamp its cancellation policies, ending a nearly six-year showdown with the Federal...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Secures a $1.1 Million Fine From Amedisys for Deficient Second Request Compliance

On August 7, 2025, the Antitrust Division of the U.S. Department of Justice (DOJ) — together with co-plaintiff attorneys general of Maryland, Illinois, New Jersey and New York (Plaintiff States) — filed a proposed settlement...more

Husch Blackwell LLP

Mid-Year Update: PPP Investigations Continue as DOJ Enforcement Priority

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As we enter the second half of 2025—over five years now since the COVID-19 pandemic began—federal government scrutiny relating to Paycheck Protection Program (PPP) loans received in the early days of the pandemic is still...more

Buchalter

California Expands Protections for Tipped Employees —New Requirements for Employers Begin January 1, 2026

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On July 30, 2025, Governor Newsom signed Senate Bill 648 into law, amending the Labor Code to strengthen protections for employee gratuities. Under the new law, if customer pays a gratuity by credit card, then the business...more

Seyfarth Shaw LLP

European Accessibility Act Poses New Challenges for US Companies with Customers in the EU

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Disability advocates issue demands to retailers about their allegedly inaccessible websites shortly after the EAA takes effect....more

WilmerHale

DOJ Announces First FCPA Enforcement Activity After Months-Long Pause

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Over the past week, the U.S. Department of Justice (“DOJ”) unsealed its first Foreign Corrupt Practices Act (“FCPA”) enforcement action and issued its first declination since the pause in FCPA enforcement mandated by...more

Ballard Spahr LLP

Rise in E-Verify Desk Audits: What U.S. Employers Need to Know in 2025

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In recent months, we have seen a notable uptick in E-Verify desk audits and related inquiries from federal and state agencies. This trend reflects the current administration’s heightened focus on employer immigration...more

Parker Poe Adams & Bernstein LLP

EEOC Settlement Emphasizes Employees' Right to Discuss Salaries

Reports of the demise of the Equal Employment Opportunity Commission’s enforcement of traditional discrimination claims may have been exaggerated. Last week, the commission announced settlement of claims made against Sinclair...more

Morrison & Foerster LLP

Understanding DOJ’s New Guidance on Unlawful Discriminatory Practices

On July 29, 2025, the U.S. Department of Justice (“DOJ”) issued a memorandum titled “Guidance for Recipients of Federal Funding Regarding Unlawful Discrimination” (the “Memo”), providing guidance on what diversity, equity,...more

Foley & Lardner LLP

SEC Intensifies Scrutiny of Chief Compliance Officers

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Two recent SEC enforcement actions serve as a sharp reminder that Chief Compliance Officers (CCOs) can face personal liability for what they do – or fail to do – in the course of regulatory examinations for registered...more

Wilson Sonsini Goodrich & Rosati

Department of Commerce Initiates Bayh-Dole Compliance Review and Asserts March-In Proceeding Targeting Harvard University Patents

On August 8, 2025, the U.S. Department of Commerce notified Harvard University (Harvard) that it has initiated a comprehensive review of Harvard’s federally funded research programs to assure compliance with the Bayh-Dole...more

Wiley Rein LLP

FTC Consumer Protection and Privacy Enforcement Series: PADFA Enforcement—What Companies Need to Know

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As part of our series to provide practical insights into emerging Federal Trade Commission (FTC) priority areas for consumer protection and data privacy enforcement, we are taking a deep dive into the Protecting Americans’...more

Husch Blackwell LLP

Precious Metals Fraud Case Invites Challenges to CFTC's Antifraud Authority

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On July 21, 2025, in Commodity Futures Trading Commission et al. v. TMTE Inc et al., a Texas district court denied summary judgment to both the Commodity Futures Trading Commission (CFTC) and two individual defendants in a...more

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