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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

White & Case LLP

CFIUS 2024 Annual Report Key Takeaways

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The Committee on Foreign Investment in the United States (CFIUS or the Committee) recently published its Annual Report to Congress covering calendar year 2024 (the Report). In many respects, the data within the Report mirrors...more

The Volkov Law Group

Cadence Design Systems Settles with DOJ and Commerce Department for Export Control Violations and Agrees to Pay $140 Million (Part...

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DOJ’s initiation of its aggressive trade enforcement strategy is quickly unfolding — and the new strategy is a real and significant threat to all companies engaged in international trade. We are no longer in the era of FCPA...more

Hughes Hubbard & Reed LLP

$140M US Export Controls Enforcement Action for ‘Reason to Know, Including Awareness of a High Probability’ Violations

On July 28, the U.S. Department of Justice’s National Security Division and the Department of Commerce’s Bureau of Industry and Security (BIS) jointly announced resolutions of parallel criminal and administrative...more

Husch Blackwell LLP

Trump Administration’s AI Action Plan and New Executive Orders Offer Strategic Opportunities and Legal Risks for Private...

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Key Point: “Winning the Race: America’s AI Action Plan,” the Trump Administration’s summary approach to federal artificial intelligence (AI) policy, and three new Executive Orders (EO) propose a wide-ranging federal strategy...more

Morrison & Foerster LLP

FTC Looks to Leverage PADFAA Enforcement to Help Limit Exposure of Consumer Data

In recent comments, Commissioner Holyoak signaled that the Federal Trade Commission will prioritize enforcement of the Protecting Americans’ Data from Foreign Adversaries Act (PADFAA), a law that empowers the FTC to police...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for June 2025

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Ropes & Gray LLP

AI and Tech under the One Big Beautiful Bill Act: Key Restrictions, Risks, and Opportunities

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On July 4, 2025, President Trump signed “The One Big Beautiful Bill Act” into law. While much attention has focused on the bill’s rejection of a proposed 10-year federal ban on state and local artificial intelligence (“AI”)...more

Wiley Rein LLP

Update: Enforcement of DOJ Data Security Program Set to Begin July 9

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The U.S. Department of Justice (DOJ) is set to enforce its sweeping new rule on certain U.S. data transactions with countries of concern and covered persons as of July 9, 2025. The new rule regarding “Preventing Access to...more

Orrick, Herrington & Sutcliffe LLP

5 Things In-House Counsel Must Know Before DOJ’s Bulk Transfer Rule Enforcement Begins

The Department of Justice’s (DOJ) 90-day grace period for compliance with the Data Security Program (DSP) ends on July 8, 2025, and enforcement is expected to begin. This regulatory regime was created for national security...more

Morrison & Foerster LLP

DOJ Issues First-Ever Declination Under Corporate Disclosure M&A Policy

On June 16, 2025, the Department of Justice (DOJ) National Security Division (NSD) announced that it declined to charge private equity firm White Deer Management LLC (“White Deer”) and its affiliates after the company...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

WilmerHale

Voluntary Disclosure of Export Control Violations is Critical for Settling Criminal Liability, DOJ Action Shows

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The Department of Justice’s (DOJ) recent announcement that it would decline to prosecute a self-reported criminal export control violation demonstrates the continuing importance of prompt, voluntary self-disclosure (VSD) and...more

Hinshaw & Culbertson - Consumer Financial...

An In-House Compliance Guide for Responding to President Trump's Executive Order on Foreign Corrupt Practices Act Enforcement

As has widely been published, on February 10, 2025, President Trump signed Executive Order (EO) 14209, which paused all future investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA) for at least...more

Troutman Pepper Locke

Trump Administration’s First Export Control Action – Reading the Tea Leaves

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On March 25, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a significant expansion of its Entity List restrictions, adding 80 entities from China, the United Arab Emirates, South Africa,...more

King & Spalding

State Criminal and Civil Liability for Material Support: How the FTO Designation of Drug Cartels Increases the Risk of State...

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The State Department’s February 20, 2025, designation of specific Mexican drug cartels and Transnational Criminal Organizations (TCOs) as foreign terrorist organizations (FTOs) creates serious new risks for businesses...more

Snell & Wilmer

Reevaluating the Foreign Corrupt Practices Act Enforcement: A New Paradigm

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On February 10, 2025, President Trump signed an Executive Order (E.O.) directing a shift in the enforcement of the Foreign Corrupt Practices Act (FCPA). The order effectively pauses new FCPA investigations and enforcement...more

Ropes & Gray LLP

Enforcement under the Trump Administration: Reports of the FCPA’s Death are Exaggerated

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On February 10, 2025, President Trump issued an executive order (the “EO”) directing the U.S. Department of Justice (“DOJ”) to pause new Foreign Corrupt Practices Act (“FCPA”) investigations and enforcement actions for 180...more

Foley Hoag LLP - White Collar Law &...

AG Bondi Overhauls FCPA Enforcement in Day 1 Memo

On February 5, 2025, on her first day in office, U.S. Attorney General Pam Bondi issued fourteen memos outlining new policies for the U.S. Department of Justice (“DOJ”) in a broad range of enforcement arenas. Among these Day...more

Vinson & Elkins LLP

White Collar and Corporate Criminal Enforcement in the Trump 2.0 Era

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When President-Elect Donald J. Trump takes office on January 20, 2025, the U.S. Department of Justice (“DOJ” or the “Department”) is certain to be at the center of the action and conversation in Washington, D.C.—just as it...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Sanctions Puzzle: Key Areas To Watch in 2025 and Beyond

The past weeks and months have brought about tremendous political change in the West, as we move toward a new U.S. administration, a new College of Commissioners in Brussels and a new Polish presidency of the Council of the...more

Skadden, Arps, Slate, Meagher & Flom LLP

OFSI Issues First Monetary Penalty for Breach of Sanctions Imposed on Russia in Response to Its Invasion of Ukraine

On 27 September 2024, the UK’s financial sanctions regulator, the Office of Financial Sanctions Implementation (OFSI), announced that it had issued its first monetary penalty for a breach of UK financial sanctions imposed...more

Morrison & Foerster LLP

Key Points from the 2023 CFIUS Annual Report

On July 23, 2024, the Committee on Foreign Investment in the United States (CFIUS or the “Committee”) released its Annual Report to Congress covering calendar year 2023. In a year that featured lower deal volume, CFIUS...more

Morrison & Foerster LLP

OFAC Year in Review 2023 – Part 1

2023 was another record year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Most prominently, OFAC continued to impose significant additional sanctions on Russia in...more

McDermott Will & Schulte

Year in Review: Criminal Enforcement by the DOJ Antitrust Division in 2023

When it comes to antitrust criminal enforcement, 2023 will be remembered as the year when the US Department of Justice’s (DOJ) Antitrust Division redefined and tested the outer boundaries of its authority. This report looks...more

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