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New Guidance Penalties

Foley & Lardner LLP

Virginia Bureau of Insurance Issues Guidance Clarifying Material Change and Required Notifications for Managed Care Health...

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On July 22, the Virginia Bureau of Insurance (BOI) issued Administrative Letter 2025-02 (the Letter) to all licensed insurers writing Managed Care Health Insurance Plans (MCHIPs) in Virginia. The Letter clarifies what...more

Jenner & Block

Recent OSHA Activity Provides Additional Mitigation Opportunities to Employers

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Recent actions by the Occupational Safety and Health Administration may provide employers additional opportunities for penalty and enforcement relief. On July 14, 2025, the U.S. Department of Labor updated OSHA penalty...more

Mintz

California Issues Additional Guidance Concerning Mandatory Climate Disclosures

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Last week, the California Air Resources Board ("CARB")--the agency responsible for implementing California's mandatory climate disclosures--issued additional guidance concerning these regulations. Significantly, although...more

Holland & Knight LLP

CFPB Provides Guidance on Referrals for Potential Criminal Enforcement

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The CFPB has issued a policy statement describing its plan to address criminally liable regulatory offenses. President Donald Trump previously issued an executive order on May 9, 2025, requiring each federal agency to publish...more

Blake, Cassels & Graydon LLP

New Guidance From Ontario’s Information and Privacy Commissioner on Privacy Management for Small Healthcare Organizations

Ontario’s Information and Privacy Commissioner (IPC) has released a new Privacy Management Handbook (Handbook) aimed at assisting small healthcare organizations to meet their privacy obligations under Ontario’s health...more

Troutman Pepper Locke

DOJ’s Revised Self-Disclosure Policy May Offer Companies More Certainty

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Last month, the DOJ Criminal Division (Division) revised its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), introducing several potentially significant changes intended to further incentivize companies to...more

Nilan Johnson Lewis PA

E-Verify Issues Guidance on Revocation of Certain Employment Authorization Documents

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On June 20, 2025, E-Verify issued guidance on certain Employment Authorization Documents (EADs) that DHS has revoked for individuals whose parole has been terminated.  The guidance advises employers to regularly generate the...more

DLA Piper

DOJ’s Revised Policy on Crediting Fines: Emphasis on Victims

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Without fanfare, the Department of Justice (DOJ or the Department) has published a memorandum revising its policy on when – and how – it will give credit to companies for fines and other payments made to other agencies,...more

DLA Piper

Belgian VAT Authorities Publish New Circular Letter Regarding Late Input VAT Recovery

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Seven years after relevant judgments from the CJEU, the Belgian VAT authorities now (broadly) allow the recovery of input VAT beyond the standard Belgian limitation period of three years, subject however to strict conditions....more

Bricker Graydon LLP

Don’t Forget About the IRS When Correcting Delinquent Plan Contributions

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Employers that do not timely deposit participant deferrals and loan contributions to their employer sponsored retirement plans can be subject to Department of Labor (DOL) penalties for breaching their fiduciary duties....more

Williams Mullen

PODCAST: Williams Mullen's Benefits Companion - Forfeitures Under Fire

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On this episode of Williams Mullen's Benefits Companion, host Brydon DeWitt unpacks the growing legal controversy surrounding the use of forfeitures in retirement plans. With numerous lawsuits recently filed, plan sponsors...more

Ropes & Gray LLP

The FCA Has Revamped its Enforcement Guide – Here’s What You Should Know

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On Tuesday the UK’s Financial Conduct Authority (FCA) issued an updated version of its Enforcement Guide, which will now be referred to as ‘ENFG’ in the FCA Handbook, to distinguish it from the previous version. The ENFG is...more

K&L Gates LLP

UK Cross-Government Review of Sanctions Implementation and Enforcement

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On 15 May 2025, the UK government published a policy paper summarising findings from a cross-government review of sanctions implementation and enforcement. The Foreign, Commonwealth and Development Office led the review in...more

Parker Poe Adams & Bernstein LLP

Department of Transportation English Proficiency Guidance Takes Effect in Late June

Last month, President Donald Trump signed an executive order directing the Department of Transportation’s Federal Motor Carrier Safety Administration (FMCSA) to begin enforcement of English language proficiency (ELP)...more

Morrison & Foerster LLP

DOJ Criminal Division Revises Its Corporate Enforcement Policy, Monitor Selection Policy, and Whistleblower Award Program

On May 12, 2025, the Criminal Division of the U.S. Department of Justice (DOJ) revised its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) and Corporate Whistleblower Awards Pilot Program (Whistleblower...more

BakerHostetler

DOJ Criminal Division Announces Leniency and Potential Declination for Companies That Self-Disclose

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Earlier this month, the DOJ’s Criminal Division Head, Matthew R. Galeotti, spoke at the Securities Industry and Financial Markets Association’s (SIFMA) Anti-Money Laundering and Financial Crimes Conference in Washington,...more

Saiber LLC

NJ DOL Proposes New Rules Clarifying the ABC Test for Independent Contractors

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The New Jersey Department of Labor and Workforce Development (NJDOL) recently issued proposed regulations aimed at clarifying how employers should apply the “ABC test” to determine whether a worker is properly classified as...more

Morrison & Foerster LLP

CFTC Advisory Outlines Materiality Criteria for Enforcement Referrals

On April 17, 2025, three operating divisions (the “Operating Divisions”) of the U.S. Commodity Futures Trading Commission (“CFTC”) and the Division of Enforcement (“DOE”) provided guidance in CFTC Letter 25-13 (the...more

Morrison & Foerster LLP

UK Serious Fraud Office Issues New Guidance on Corporate Cooperation and Enforcement

On 24 April 2025, the UK’s Serious Fraud Office (SFO) published new guidance for companies on cooperation and enforcement in relation to corporate criminal offending (Guidance). The Guidance outlines the SFO’s key...more

Dacheng

China Monthly Antitrust Update: April 2025

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This monthly report outlines key developments in China’s antitrust sector for April. The following events merit special attention...more

Troutman Pepper Locke

DOJ’s Latest Guidance on the Data Security Program – What’s New?

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The new Department of Justice (DOJ) Data Security Program (DSP) took effect on April 8....more

Ogletree, Deakins, Nash, Smoak & Stewart,...

CFTC Unveils Replacement Penalty Mitigation Policy Focused on Self-Reporting, Cooperation, and Remediation

The Commodity Futures Trading Commission (CFTC), an independent U.S. government agency that regulates the U.S. derivatives markets, including futures, options, and swaps, has announced a new policy for mitigating potential...more

Husch Blackwell LLP

New Federal Noncitizen Registration Requirement Guidance for Employers and Noncitizen Employees

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On January 20, 2025, President Donald Trump issued an Executive Order titled “Protecting the American People Against Invasion,” which directs the Department of Homeland Security (DHS) to enforce a long-dormant noncitizen...more

Baker Botts L.L.P.

CFTC Issues Enforcement Advisory Adopting New Approach for Consideration of Self-Reporting, Cooperation, and Remediation

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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

Bowditch & Dewey

Corporate Transparency Act – Yes, it’s Back, but no Fines or Penalties for Now

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On February 27, 2025, in a move to comply with the Treasury’s commitment to reducing regulatory burdens on businesses, FinCEN announced that it will not impose fines or penalties or take other enforcement actions against any...more

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