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Penalties Disclosure Requirements Enforcement Actions

Holland & Knight LLP

SEC Scorches New Mexico Investment Advisers for Allegedly Defrauding Elderly Clients

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The SEC on June 2, 2025, filed a complaint against David A. Nagler and New Line Capital LLC (Defendants) in the U.S. District Court for the District of New Mexico for allegedly breaching their fiduciary duties and defrauding...more

Wiley Rein LLP

With “Click-to-Cancel” Rule Now Vacated by 8th Circuit, What’s Next for FTC?

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The U.S. Court of Appeals for the Eighth Circuit on July 2 issued a decision vacating the Federal Trade Commission’s (FTC) revised Negative Option Rule, which the previous Administration called the “Click to Cancel” Rule....more

Fox Rothschild LLP

Connecticut AG Announces $85,000 CTDPA Fine

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Connecticut Attorney General William Tong recently announced his office’s first enforcement action for violations of the Connecticut Data Privacy Act. “This law has now been in effect for two years,” Tong said in a...more

Sheppard Mullin Richter & Hampton LLP

DFPI Finalizes $300,000 Settlement with Crypto Kiosk Operator for Alleged Digital Asset Law Violations

On June 25, the California DFPI announced that it had finalized a consent order with a cryptocurrency kiosk operator, alleging violations of the Digital Financial Assets Law (DFAL) and the California Consumer Financial...more

Ropes & Gray LLP

Navigating TRAIGA: Texas’s New AI Compliance Framework

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On June 22, 2025, Texas enacted the Texas Responsible Artificial Intelligence Governance Act (“TRAIGA”), putting it at the forefront of state-level AI regulation in the United States. TRAIGA becomes effective January 1, 2026....more

BCLP

Upper Tribunal Ruling in the Case of Craig Donaldson and David Arden (Metro Bank)

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The Upper Tribunal has upheld the FCA’s decision that the CEO and CFO of Metro Bank were knowingly concerned in the Bank’s breach of the Listing Rules....more

Davies Ward Phillips & Vineberg LLP

A Strong Signal: AMF Adopts a Policy Supporting Self-Reporting and Cooperation

The Autorité des marchés financiers (AMF), the body responsible for enforcing Québec’s legislation concerning the financial sector, recently adopted a Self-Reporting and Cooperation Policy. The policy, adopted on May 20,...more

The Volkov Law Group

Episode 371 -- DOJ's New Corporate Enforcement Program

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Is your company ready to bet its future on whether it can outpace a whistleblower to the DOJ’s door? In this episode, Michael Volkov takes a deep dive into the Department of Justice’s newly announced strategy to reshape...more

Fox Rothschild LLP

Franchise Enforcement Trends: Are States Cracking Down on Non-Compliance?

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If you think franchise compliance is just a box to check, think again. As part of my presentation on Annual Developments in Franchise Law at the most recent ABA Forum on Franchising Annual Meeting, I did a deep dive into...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

Hogan Lovells

Deceptive sweepstakes prompt FTC action and consumer payouts

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Last week, the Federal Trade Commission sent more than $18 million in refunds to U.S. consumers who entered a Publishers Clearing House (PCH) sweepstakes in recent years. The refund represents a significant remedy to...more

The Volkov Law Group

Reviewing the CPB Enforcement Process Under 19 U.S.C. § 1592 (Part II of II)

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CPB’s administrative enforcement program is robust and increasing, especially with the importance of trade and tariff enforcement.  There are a lot of “ins and outs” (Big Lewbowski Here) to the administrative process which...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

Proskauer - Regulatory & Compliance

EU Regulators Take Different Enforcement Paths for ESMA ESG Fund Name Guidelines

European regulators have taken different routes as to how they plan to enforce the European Securities and Markets Authority’s (“ESMA”) guidelines (the “Guidelines”) with respect to the use of sustainability‑related terms in...more

Holland & Knight LLP

Colleges and Universities Must Report Certain Foreign Gifts and Contracts

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In light of recent enforcement activity, institutions of higher education should review their reporting and disclosure obligations related to foreign entities and individuals under Section 117 of the Higher Education Act (20...more

Davis Wright Tremaine LLP

CFTC Eliminates PTMMM Disclosure Requirements for Swap Entities

On April 4, 2025, the CFTC's Division of Market Participants issued No-Action Letter 25-09 regarding the controversial Pre-Trade Mid-Market Mark ("PTMMM") requirements in CFTC Regulation 23.431, effectively eliminating the...more

Butler Snow LLP

Treasury Department Limits Enforcement of the Corporate Transparency Act

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The Treasury Department announced on March 2nd that it does not intend to enforce any penalties or fines against either U.S. citizens or domestic reporting companies and their beneficial owners under the Corporate...more

Fox Rothschild LLP

Corporate Transparency Act Back in Effect

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The Corporate Transparency Act’s (CTA) reporting requirements are officially back in force, requiring non-exempt entities to disclose beneficial ownership information (BOI). This week, a Texas federal court lifted the last...more

Kerr Russell

The Corporate Transparency’s Act’s Impact on Medical Practices: Understanding Physicians’ Obligations Amid Recent Judicial and...

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Medical practices across the United States are grappling with new compliance obligations under the Corporate Transparency Act (CTA). This article addresses the CTA’s applicability to medical practices, its current legal...more

Perkins Coie

Securities Enforcement Forum New York 2025: A New Era Looms

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Senior Division of Enforcement (Division) officials from the U.S. Securities and Exchange Commission (SEC or Commission) spoke with SEC alumni, private practitioners, and other professionals at the Securities Enforcement...more

White & Case LLP

SEC Charges Investment Adviser - Signaling Importance of Accurate Disclosure of AML Procedures

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The U.S. Securities & Exchange Commission ("SEC") recently announced settled charges against an investment adviser for misrepresentations regarding its anti-money laundering ("AML") procedures and compliance failures. As we...more

Foley & Lardner LLP

SEC Actions in Review: What Officers and Directors Should Know for 2025

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As the regulatory landscape continues to evolve, public company officers and directors must stay abreast of the enforcement priorities and expectations of the Securities and Exchange Commission (SEC). Over the past year, the...more

Foley & Lardner LLP

SEC Settlement Highlights Importance of Proper Disclosure Requirements for Private Fund Managers

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On January 10, 2025, the Securities and Exchange Commission (SEC) settled charges against two fund managers (collectively the “Fund Managers”) and their sole owner, chief executive office, chief compliance office, and founder...more

Freeman Law

National Taxpayer Advocate’s Annual Report Highlights Issues Plaguing the IRS

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In her annual report to Congress for 2024, National Taxpayer Advocate (“NTA”) Erin M. Collins identified the processing of Employee Retention Credits (“ERCs”), the administration of civil penalties, and changes to the...more

Cooley LLP

Public Companies Update – December 2024 One-Minute Reads

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SEC’s Office of the Whistleblower annual report - On November 15, 2024, the Securities and Exchange Commission’s Office of the Whistleblower released its annual report to Congress. The Whistleblower Program report includes...more

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