News & Analysis as of

Investigations Disclosure Requirements

Herbert Smith Freehills Kramer

The NSTA’s New Disclosure Policy

On 31 July 2025, the North Sea Transition Authority (NSTA) confirmed its new approach to regulatory transparency by announcing its intention to publicly name companies subject to ongoing investigations and those who fail to...more

Mintz

Florida AG Announces Investigation into Climate Nonprofits for Alleged Violations of Consumer Protection and Antitrust Laws Based...

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3 On July 28, 2025, the Republican Attorney-General of Florida announced that his office had “issued subpoenas to investigate whether the CDP (formerly the Climate Disclosure Project) and the Science Based Targets Initiative...more

Vedder Price

Florida AG Investigation Is Latest Reminder of Risk Tied to Green Initiatives

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Florida’s Attorney General announced an investigation on July 28, 2025 into whether the CDP (formerly known as the Climate Disclosure Project) and the Science Based Targets Initiative (SBTi) have violated consumer protection...more

Hanson Bridgett

Court Broadens CPRA Access to Police Shooting Investigations

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City of Vallejo v. Superior Court (2025) 112 Cal.App.5th 565. A recent California appellate court decision has significant implications for the scope of SB 1421 (enacted in 2018), providing a broad reading to Penal Code §...more

K&L Gates LLP

Key Takeaways From the UK Financial Conduct Authority's Revised Enforcement Guide

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Following a two-part consultation, which began in February 2024 (i.e., CP 24/2 and CP 24/2: Part 2) and was accompanied by a Policy Statement (PS25/5) setting out the UK Financial Conduct Authority’s (FCA) consultation...more

Hogan Lovells

UK Financial Conduct Authority publishes its revised Enforcement Guide

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The UK’s Financial Conduct Authority (FCA) has published Policy Statement PS25/5, Our Enforcement Guide and greater transparency of our enforcement investigations, setting out the changes it is making to its Enforcement Guide...more

A&O Shearman

The FCA’s revised Enforcement Guide: Key policy changes to be aware of

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The UK Financial Conduct Authority (FCA) has updated its Enforcement Guide, including its revised policy on when it will announce details of enforcement investigations. Following a consultation process that was subject to...more

Maynard Nexsen

When Firms Receive Written Notice of Outside Business Activities

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In the world of outside business activity (OBA) disclosure, many FINRA enforcement actions center on whether a registered person gave, or did not give, prior written notice of those activities to their member firm. These...more

Snell & Wilmer

FARA's Pendulum: Shifts in Foreign Agent Regulation

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On her first day in office, Attorney General Pamela Bondi issued a memorandum signaling a significant shift in the Department of Justice’s (DOJ) approach to Foreign Agents Registration Act (FARA) enforcement. The memorandum...more

Faegre Drinker Biddle & Reath LLP

Things I Worry About (8): DOL Investigations and Unsuspecting Plan Sponsors (2)

As explained in my last post, Things I Worry About (7), the DOL’s EBSA has a number of programs that can restore benefits to plans and participants. Those include: - Civil investigations. - Criminal investigations. -...more

Ankura

The CFPB Sets Its Sights on Buy Now, Pay Later Lenders in New Interpretive Rule

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On May 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule identifying Buy Now, Pay Later Lenders (BNPL Lenders or Lenders) as “card issuers” or “creditors” for the purposes of Regulation Z,...more

Pillsbury Winthrop Shaw Pittman LLP

Disclosure of Non-GAAP Financial Measures: Recent SEC Comments and Enforcement Actions

The U.S. Securities and Exchange Commission (SEC) continues to scrutinize adjustments to, and presentation of, non-GAAP financial measures. Recent SEC enforcement actions for allegedly improper and misleading use of...more

Health Care Compliance Association (HCCA)

In This Month’s E-News: November 2024

On the heels of a $7.6 million payment by Cleveland Clinic to settle allegations of False Claims Act (FCA) violations and unallowable sharing of passwords, Michael Lauer, NIH deputy director for extramural research, penned a...more

Woodruff Sawyer

Close, but No Cigar: Ensuring Accuracy in Public Disclosures

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A recent enforcement action by the Securities and Exchange Commission (SEC) highlights the risks companies face when public disclosures may be viewed as misleading or fail to account for updated information....more

Bradley Arant Boult Cummings LLP

Unfair and Deceptive Cookie Banners: The Next Wave of Privacy Litigation?

Today, encountering a cookie banner is a common experience for most individuals who peruse the internet. These banners inform website users of the presence of cookies or other tracking technologies through language such as,...more

Proskauer Rose LLP

Regulation Round Up - August 2024 - 2

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Welcome to the Regulation Round Up, a regular bulletin highlighting the latest developments in UK and EU financial services regulation....more

King & Spalding

N.Y. Attorney General Issues Guidance for Internet Privacy Tools

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On July 15, 2024, the Office of the New York State Attorney General (OAG) announced new guidance regarding the use of cookies, tags, and other online user information tracking tools. Although New York does not yet have a...more

Proskauer - Tax Talks

Proposed Regulations Issued on Reporting Obligations for Basket Contract Transactions

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On July 12, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations that would classify “basket contract transactions”, which are derivatives (i) with a term...more

Bracewell LLP

Creating an Army of In-House Investigators

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In its never-ending war on corporate fraud, the Department of Justice (“DOJ”) has just commissioned a private army to fight as never before. On August 1, the DOJ launched a three-year program to provide financial rewards to...more

ArentFox Schiff

OCR Finalizes HIPAA Privacy Rule to Support Reproductive Health Care Privacy

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On April 26, the US Department of Health and Human Services Office for Civil Rights (OCR) published a Final Rule that adds protections under the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule...more

ArentFox Schiff

Continuing Forward: Senate Leaders Release an AI Policy Roadmap

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The US Senate’s Bipartisan AI Policy Roadmap is a highly anticipated document expected to shape the future of artificial intelligence (AI) in the United States over the next decade. This comprehensive guide, which complements...more

Foley Hoag LLP - White Collar Law &...

Tennessee v. BlackRock: How this Case Informs How We Look Back and Look Ahead at ESG

This is the final post in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year... Politicians in Republican-led states have painted a target on environmental,...more

Akin Gump Strauss Hauer & Feld LLP

Cross-Border Implications of the FCA’s Consultation Paper on Publishing Information About the Opening and Progress of...

Last month, the United Kingdom Financial Conduct Authority (FCA) announced that it is considering new procedures under which it would publicly identify firms that are under investigation as soon as the investigation has been...more

American Conference Institute (ACI)

[Event] The Brazil Summit on Anti-Corruption, Integrity & ESG - May 22nd - 23rd, São Paulo, Brazil

Hosted by American Conference Institute, the 14th Annual Summit on Anti-Corruption, Integrity & ESG returns to Brazil for another groundbreaking year to discuss the current high-stakes dilemmas impacting your organization....more

Bracewell LLP

The ENRC Saga – Not Just a UK Concern

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On 21 December 2023, Mr Justice Waksman handed down his judgment in the second trial of the Eurasian Natural Resources Corporation (ENRC) saga. The judgment, along with its earlier companions, is extraordinary in many ways...more

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