News & Analysis as of

Enforcement Actions Risk Management Civil Monetary Penalty

Womble Bond Dickinson

The ICO’s Penalty Against 23andMe Brings New Emphasis on Cybersecurity Risks - Key Takeaways for U.S. Companies

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The dramatic increase in global reach that the internet provides U.S.-based companies comes as a double edge sword. While it significantly increases a company’s potential customer pool, it also subjects companies to...more

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

SPCC Enforcement/Clean Water Act: U.S. Environmental Protection Agency and Tupelo, Mississippi Oil Storage Facility Owner Enter...

The United States Environmental Protection Agency (“EPA”) Khera Petroleum, LLC (“KP”) entered into a June 11th Consent Agreement (“CA”) addressing alleged violations of the Clean Water Act Spill Prevention, Control, and...more

Jackson Lewis P.C.

Employers Won’t Face Double Damages from DOL Wage and Hour Division’s Administrative Proceedings

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The U.S. Department of Labor’s Wage and Hour Division (WHD) has issued new internal guidance that significantly changes its approach to administrative settlements under the Fair Labor Standards Act (FLSA). In Field Assistance...more

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

112(r)(7)/Air Enforcement: U.S. Environmental Protection Agency and Cactus, Texas Beef Processing Facility Enter into Expedited...

The United States Environmental Protection Agency (“EPA”) and Cactus Beef Processing Facility (“Cactus”) entered into a May 15th Expedited Settlement Agreement (“ESA”) addressing an alleged violation of Section 112(r(7) of...more

Ropes & Gray LLP

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

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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

Jenner & Block

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

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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

Katten Muchin Rosenman LLP

Clearer Skies Ahead: CFTC Enforcement Division's New Advisory Opens Doors for Self-Reporting and Increased Cooperation

In what is being widely viewed as a welcome breath of fresh air, the Commodity Futures Trading Commission (the Commission or CFTC) Division of Enforcement (the Division) released an advisory on February 25, detailing the...more

DLA Piper

False Claims Act Year in Review: 2024

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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

Husch Blackwell LLP

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

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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

Health Care Compliance Association (HCCA)

We’ll Take the Fine: OCR’s ‘Unwarranted,’ Costly Demands Prompted Hospital’s $538K Payment

The saga that led Children’s Hospital Colorado to accept a fine of more than $500,000 imposed by the HHS Office for Civil Rights (OCR) began on July 11, 2017, when a physician’s email account containing details on 3,300...more

The Volkov Law Group

Córdoba Music Group Settles with OFAC for $41,591 for Violations of Iran Sanctions Program

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Córdoba Music Group LLC (Córdoba), a manufacturer of musical instruments based in California, has agreed to pay $41,591 to settle its civil liability for violations of sanctions on Iran. On nine occasions, Córdoba shipped...more

The Volkov Law Group

C.H. Robinsom Settles with OFAC for $257,690 to Resolve Iran and Cuba Sanctions Violations

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C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba...more

BCLP

2024 CFTC Enforcement: Agency Celebrates Record Monetary Relief

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On December 4, 2024, the Commodity Futures Trading Commission (“CFTC”) released its enforcement results for Fiscal Year 2024 (“FY 2024”), showcasing record awards of monetary relief totaling more than $17.2 billion....more

Wiley Rein LLP

Dissenting Commissioners Criticize SEC’s Latest Cybersecurity Disclosure Cases

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Continuing its controversial and aggressive approaches to cybersecurity, the U.S. Securities and Exchange Commission (SEC) recently charged four current and former public companies for purportedly “materially misleading...more

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for July 2024

SEC Loses in ALJ Case, DOL’s Latest Fiduciary Rule Put on Hold, and SEC Reconsiders AI and Custody Rule Proposals - Welcome to our July Regulatory Roundup, where we provide a quick look at the latest regulatory developments....more

ArentFox Schiff

Disclosing Patient Information in Responses to Online Reviews: Recent OCR Enforcement Action Is a Cautionary Tale

ArentFox Schiff on

The HHS Office for Civil Rights (OCR) recently imposed a $50,000 civil monetary penalty on a dental practice that disclosed patient-identifying information in response to a negative online review. The case is a reminder that...more

Baker Donelson

Cybersecurity: A Whistleblower's Paradise

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Cyber whistleblowing is the newest and hottest area of exposure for organizations. All government contractors and grant recipients must develop an understanding of the use of the False Claims Act (FCA) to address...more

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

112(r)(1)/Air Enforcement: U.S. Environmental Protection Agency and Arlington, Massachusetts, Arena/Ice Skating Rink Enter into...

The United States Environmental Protection Agency (“EPA”) and Town of Arlington, Massachusetts (“Arlington”), entered into a January 19th Expedited Settlement Agreement (“ESA”) addressing an alleged violation of Section...more

Holland & Knight LLP

SEC Issues First-Ever Penalties for Deficient Cybersecurity Risk Controls

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The U.S. Securities and Exchange Commission (SEC) has launched a stunning salvo across the bows of public companies with its announcement of civil monetary penalties and a cease-and-desist order against First American...more

Health Care Compliance Association (HCCA)

Citigroup pays $400 million and must overhaul internal controls

Compliance Today (January 2021) - Just a few months before Jane Fraser takes over as chief executive officer—the first woman to run a major Wall Street bank —Citigroup agreed to pay $400 million to settle an Office of the...more

The Volkov Law Group

Citigroup Fined $400 Million by Banking Regulators for Risk and Compliance Control Deficiencies

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Banking regulators, the Office of Comptroller of the Currency and the Federal Reserve, recently collected a $400 million civil penalty against Citigroup for long-standing deficiencies in its enterprise risk management,...more

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

112(r)/Air Enforcement: U.S. Environmental Protection Agency and Williamsport, Maryland, Grocery Store Owner Enter into Expedited...

The United States Environmental Protection Agency (“EPA”) and Save-A-Lot Food Stores, Ltd. (“Save-A-Lot”) entered into a November 2nd Expedited Penalty Action and Consent Agreement (“Consent Agreement”) addressing alleged...more

WilmerHale

CFTC Enforcement Division Issues Compliance Program Guidance

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On September 10, 2020, the Commodity Futures Trading Commission’s (CFTC, or the Commission) Division of Enforcement (Division) director issued a memorandum to Division staff setting forth a framework for evaluating the...more

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