News & Analysis as of

Enforcement Actions Civil Monetary Penalty Compliance

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

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

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

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

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

Air Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Searcy Compression Station...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“DEQ”) and Merit Energy Company, LLC (“Merit”) entered into a May 15th Consent Administrative Order (“CAO”) addressing an alleged...more

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

Storage Tank Enforcement: Tennessee Department of Environment and Conservation Proposed Order Addressing Covington, Tennessee...

The Tennessee Department of Environment and Conservation (“TDEC”) issued a June 18th Proposed Order and Assessment (“Order”) to Diamond Investments of TN Inc. (“Diamond”) addressing an alleged violation of underground storage...more

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

Stormwater Enforcement: Colorado Department of Public Health & Environment and La Plata County Mining Operator Enter into...

The Colorado Department of Public Health & Environment (“Department”) and Sunrise Mining, LLC (“Sunrise”) entered into a May 14th Compliance Order on Consent (“CO”) addressing an alleged violation of the Colorado Stormwater...more

Skadden, Arps, Slate, Meagher & Flom LLP

OFSI Issues First-Ever Monetary Penalty for a Failure To Provide Information: Key Considerations for Companies

The Offence and Penalty - On 8 May 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) published its 11 April 2025 notice of its first-ever monetary penalty for an information offence relating to financial...more

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

Storage Tank Enforcement: Tennessee Department of Environment and Conservation and Jackson Facility Enter into Agreed Final Order

The Tennessee Department of Environment and Conservation (“TDEC”) and Bowling Convenience, Inc. (“BCI”) entered into an April 4th Agreed Final Order (“AFO”) addressing alleged violations of the Tennessee Underground Storage...more

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

Efficiency Standards Enforcement: California Energy Commission and City of Industry Computer Manufacturer Enter into Settlement...

The California Energy Commission (“CEC”) and Sceptre, Inc. (“SI”) entered into an March 24th Settlement Agreement and Release (“Settlement”) addressing alleged violations of Appliance Efficiency Regulations at California Code...more

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

Storage Tank Enforcement: Tennessee Department of Environment and Conservation and Knoxville Facility Enter into Agreed Final...

The Tennessee Department of Environment and Conservation (“TDEC”) and Ziptron Energy, Inc. (“ZEI”) entered into an April 4th Agreed Final Order (“AFO”) addressing alleged violations of the Tennessee Underground Storage Tank...more

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

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Huntsville Circuit Board Manufacturing Facility...

The Alabama Department of Environmental Management (“ADEM”) and Sanmina Corporation (“SC”) entered into a Consent Order (“CO”) addressing alleged violations of the Alabama Hazardous Waste Regulations. See Consent Order No....more

Ropes & Gray LLP

OFSI Annual Review 2023-2024: A Shift Towards Proactive Sanctions Enforcement and Enhanced Industry Engagement

Ropes & Gray LLP on

On 21 March 2025, the Office of Financial Sanctions Implementation (OFSI) published its annual review for 2023-2024 period. The report highlights a number of key developments in the agency’s work. Importantly, the data...more

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

Air Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Springdale Baking Facility...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“DEQ”) and Newly Weds Foods, LLC (“NWF”) entered into a March 25th Consent Administrative Order (“CAO”) addressing and alleged violation...more

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

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Marshall County Specialty Tank Manufacturer Enter...

The Alabama Department of Environmental Management (“ADEM”) and Pinnacle Manufacturing, LLC (“Pinnacle”) entered into a March 5th Consent Order (“CO”) addressing alleged violations of the Alabama Hazardous Waste regulations....more

Saul Ewing LLP

OCR Imposes $200,000 Civil Money Penalty Against HIPAA-Covered Entity

Saul Ewing LLP on

On March 6, 2025, the U.S. Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) announced a civil money penalty (“CMP”) of $200,000 against Oregon Health & Science University (“OHSU”) for failing to...more

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

Air Enforcement: Missouri Department of Natural Resources and St. Charles Retail Motor Fuel Facility Enter into Administrative...

The Missouri Department of Natural Resources (“MDNR”) and Mac’s Convenience Stores LLC (“Mac’s”) entered into a February 26th Administrative Order on Consent (“AOC”) addressing an alleged violation of the Missouri Air...more

Jenner & Block

Client Alert: CFTC Issues New Enforcement Advisory Aiming to Incentivize Self-Reporting and Cooperation

Jenner & Block on

On February 25, 2025, the Division of Enforcement (the “Division”) of the Commodity Futures Trading Commission (the “CFTC” or “Commission”) issued an Enforcement Advisory which quantifies the monetary credit that entities can...more

DLA Piper

False Claims Act Year in Review: 2024

DLA Piper on

The US government and private plaintiffs use the False Claims Act (FCA) – a federal statute originally enacted in 1863 in response to defense contractor fraud during the American Civil War – to combat various forms of fraud...more

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

Air Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Air Curtain Incinerator...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“DEQ”) and Abide Farms, LLC (“Abide”) entered into a February 12th Consent Administrative Order (“CAO”) addressing an alleged violation of...more

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

Air Enforcement: Tennessee Air Pollution Control Board Proposed Order Addressing Carthage Aluminum Extrusion Facility

The Tennessee Air Pollution Control Board issued a February 24th Technical Secretary’s Proposed Order and Assessment of Civil Penalty (“Order”) to Bonnell Aluminum, Inc. (“Bonnell”) addressing an alleged Air Permit violation....more

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

Alston & Bird

Enter the Matrix: CFTC’s New Framework for Self-Reporting, Cooperation, and Remediation

Alston & Bird on

Our White Collar, Government & Internal Investigations Group analyzes new enforcement guidance from the Commodity Futures Trading Commission (CFTC) that aims to incentivize self-reporting of potential violations....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

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

Air Enforcement: Mississippi Commission on Environmental Quality and Jonestown Cottonseed Oil Mill Owner Enter into Agreed Order

The Mississippi Commission on Environmental Quality (“MCEQ”) and Cottonseed Co Op Corporation (“CCC”) entered into an October 25th Agreed Order (“AO”) addressing alleged violations of a Title V Operating Permit. See Order No....more

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

Stormwater Enforcement: US Environmental Protection Agency and Leesville, South Carolina Timber Products Facility Enter Into...

The United Stated Environmental Protection Agency (“EPA”) and South Carolina Pole and Piling, Inc (“SCPPI”) entered into a February 11th Expedited Settlement Agreement and Final Order (“Agreement”) addressing alleged...more

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

Wastewater Enforcement: Alabama Department of Environmental Management and Jefferson County Coal Preparation Plant Enter into...

The Alabama Department of Environmental Management (“ADEM”) and Crimson Oak Grove Resources, LLC (“Crimson”) entered into a February 13th Consent Order (“CO”) addressing alleged violations of the clean water act national...more

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