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BakerHostetler

In Case of First Impression, Looking to AKS Precedent, Ninth Circuit Affirms EKRA Conviction for Improper Payments to Marketers

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In one of the few prosecutions based on the Eliminating Kickbacks in Recovery Act (EKRA), and in an even rarer Court of Appeals opinion interpreting the statute, the Ninth Circuit in United States v. Schena, No. 23-2989, 2025...more

Husch Blackwell LLP

CFTC Enforcement Division Issues Framework for DOJ Criminal Referrals

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On July 9, 2025, the Commodity Futures Trading Commission (CFTC) Division of Enforcement (DOE), acting pursuant to a recent executive order (EO), issued an advisory letter outlining its new policy for referring criminally...more

Jones Day

Landmark Enforcement Under U.S. CPSA Leads to Sentencing of Corporate Executives for Failure to Report Product Hazards

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In June 2025, two former executives were each sentenced to more than three years in prison for conspiracy and failure to report hazardous products to the U.S. Consumer Product Safety Commission ("CPSC"), marking the first...more

Cooley LLP

CFPB Announces Plan to Review Offenses Carrying Criminal Penalties

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On June 27, the Consumer Financial Protection Bureau (CFPB) issued a policy statement, “Guidance on Referrals for Potential Criminal Enforcement,” which outlines its plan to address criminal regulatory offenses within its...more

Husch Blackwell LLP

Updated: Trump Administration Clarifies Criminal Enforcement Priorities

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On May 9, 2025, the White House issued an executive order, titled “Fighting Overcriminalization in Federal Regulations,” that could have a significant impact on the administration’s enforcement of criminal regulatory...more

Orrick, Herrington & Sutcliffe LLP

CFPB publishes policy statement on criminally liable regulatory offenses

On June 27, the CFPB published a policy statement in the Federal Register outlining its plan to address criminally liable regulatory offenses. The statement came in response to Executive Order 14294, which the President...more

Cooley LLP

First-Ever Sentencing of Corporate Executives for Failure to Report Under Consumer Product Safety Act

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As we previously reported, in November 2023, two corporate executives were convicted of conspiracy and failure to report defective dehumidifiers in violation of the Consumer Product Safety Act (CPSA). This groundbreaking...more

The Volkov Law Group

Episode 374 -- Justice Department Resumes FCPA Enforcement with New, Focused Guidance

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The Justice Department has returned to the FCPA enforcement arena -- in a significant development, DOJ announced the resumption of FCPA enforcement, with a new set of enforcement guidance principles. The new guidance is an...more

Foley & Lardner LLP

FERC Issues Guidance on Treatment of Criminal Regulatory Offenses

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On June 16, 2025, the Federal Energy Regulatory Commission (FERC) issued a Notice of Guidance regarding the consistency of its existing policies for referring alleged criminal regulatory offenses to the Department of Justice...more

Brownstein Hyatt Farber Schreck

New Executive Order Takes Aim at the Regulatory State

On May 9, President Trump signed Executive Order (EO) 14294, “Fighting Overcriminalization in Federal Regulations.” The EO is a continuation of President Trump’s larger effort to address the “overregulation” problem that has...more

Husch Blackwell LLP

Trump Administration Clarifies Criminal Enforcement Priorities

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On May 9, 2025, the White House issued an executive order, titled “Fighting Overcriminalization in Federal Regulations,” that could have a significant impact on the administration’s enforcement of criminal regulatory...more

Cooley LLP

New Executive Order Seeks to Curb Overuse of Criminal Actions Brought By Federal Agencies

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Last week, President Trump issued an executive order – entitled “Fighting Overcriminalization in Federal Regulations” – with the goal of curbing the use of criminal penalties otherwise imposed by federal regulations. The...more

Sheppard Mullin Richter & Hampton LLP

DOJ’s Updated Enforcement Policy: A Game-Changer for Corporate America?

On May 12, 2025, the U.S. Department of Justice (DOJ) announced a major overhaul of its corporate enforcement policy, aiming to incentivize companies to voluntarily self-disclose misconduct. Titled “Focus, Fairness, and...more

Foley & Lardner LLP

What Every Multinational Company Needs to Know About … Criminal Enforcement of Trade, Import, and Tariff Rules: A Growing Risk for...

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In less than 100 days, the Trump administration has implemented a dizzying array of new tariffs, significantly increasing costs and complexity for U.S. importers. The administration is keenly aware that companies operating in...more

Kerr Russell

Registration and Fingerprinting Requirements for Foreign Nationals

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Beginning April 11, 2025, the U.S. Citizenship and Immigration Service will enforce provisions requiring all non-U.S. citizens over age 14 register and be fingerprinted if they are in the U.S. for at least 30 days and have...more

Mintz - Immigration Viewpoints

Alien Registration Rule and Evidence of Registration

On March 12, 2025, the Department of Homeland Security (DHS) issued an interim final rule (IFR) implementing an Alien Registration requirement. The rule takes effect on April 11, 2025. As previewed in our prior alert, this...more

Latham & Watkins LLP

Recent Developments for UK PLCs - March 2025

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On 6 February 2025, the House of Lords Financial Services Regulation Committee published a report titled “Naming and shaming: how not to regulate”....more

Hogan Lovells

Not a paper tiger – first criminal conviction for non-compliance with Hong Kong Competition Commission’s investigation powers

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On 28 February 2025, the Hong Kong Competition Commission (“HKCC”) welcomed the first criminal conviction against an individual for disposing of and concealing documents required to be produced under the HKCC’s investigation...more

Holland & Knight LLP

Former MoviePass Executive Consents and Pleads Guilty in Parallel SEC and DOJ Cases

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In Hollywood, the sequel (or, even more so, the third installment) is rarely as good as the original movie. In the world of enforcement, the same rings true....more

Hogan Lovells

The Sword and the Scales: Enforcement and restraint in the ongoing development of Singapore’s AML framework

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The Singapore Anti-Money Laundering and Other Matters Act 2024 (the “Act”), which came into effect at the end of 2024, concluded a year of legislative developments in Singapore that were aimed at strengthening the country’s...more

Saul Ewing LLP

The Foreign Agents Registration Act: 2024 Year in Review and Outlook for 2025

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Executive Summary - We entered 2025 with the world in turmoil, a new American administration in the White House, and various global actors—friends and foes alike—still actively vying for the attention of the American public. ...more

Fox Rothschild LLP

“You Have the Right to Remain Silent” . . . Criminalization of Aviation Accidents

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In the second in our Aviation Symposium series of blog posts, we present the materials from the great panel we had discussing the criminalization of aviation accidents. We were fortunate enough to have renowned criminal...more

Greenbaum, Rowe, Smith & Davis LLP

Criminalizing Reproductive Care and Abortion Services through Telehealth

The January 30, 2025 issue of the New England Journal of Medicine contains an article entitled “Providing Interstate Telehealth Abortion Services to Patients in Restrictive States.” In the second sentence, the authors write:...more

ArentFox Schiff

Three Actions to Take in Response to the DOJ’s New Corporate Enforcement Priorities

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Last week, Attorney General Pamela Bondi issued 14 memoranda outlining new enforcement priorities at the US Department of Justice (DOJ). Notably, DOJ resources will shift away from the Foreign Corrupt Practices Act (FCPA) and...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments: 2024 Year in Review

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this special edition of our award-winning monthly Top 10 International Anti-Corruption Developments newsletter summarizes the most...more

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