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Penalties Regulatory Reform Enforcement Actions

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

Proskauer - Regulatory & Compliance

Tougher UK Sanctions Penalties on the Horizon as Consultation is Launched

On 22 July 2025, the UK’s Office of Financial Sanctions Implementation (“OFSI”) published a consultation paper proposing significant reforms to its civil enforcement processes. The proposals aim to enhance the effectiveness,...more

Husch Blackwell LLP

CFTC Enforcement Division Issues Framework for DOJ Criminal Referrals

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On July 9, 2025, the Commodity Futures Trading Commission (CFTC) Division of Enforcement (DOE), acting pursuant to a recent executive order (EO), issued an advisory letter outlining its new policy for referring criminally...more

Littler

OSHA Issues Updated Penalty and Debt Collection Guidelines to Support Small Businesses and Encourage Prompt Hazard Abatement

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On July 14, 2025, the U.S. Occupational Safety and Health Administration (OSHA) issued significant updates to its penalty and debt collection guidelines, aimed at reducing burdens on small businesses and incentivizing swift...more

Paul Hastings LLP

Updates on Environmental Criminal Law in France

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Environmental criminal law in France has developed steadily over the past several years. Recently, however, there has been a shift of the political narrative — both in Europe and domestically — toward simplification rather...more

Troutman Pepper Locke

DOJ Antitrust Unit Launches Whistleblower Rewards Program

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The U.S. Department of Justice, Antitrust Division (DOJ) has announced a new initiative aimed at enhancing the detection and prosecution of antitrust violations. ...more

Orrick, Herrington & Sutcliffe LLP

CFPB publishes policy statement on criminally liable regulatory offenses

On June 27, the CFPB published a policy statement in the Federal Register outlining its plan to address criminally liable regulatory offenses. The statement came in response to Executive Order 14294, which the President...more

Troutman Pepper Locke

In Response to the President’s Directive, CFPB Unveils New Strategy to Tackle Criminal Regulatory Offenses

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Today, the Consumer Financial Protection Bureau (CFPB or Bureau) published a policy statement in the Federal Register outlining its approach to addressing criminally liable regulatory offenses. This publication comes in...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

Burr & Forman

OSHA in 2025: Key Updates and What Employers Should Know

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Workplace safety initiatives continue to evolve amid the shifting political landscape and regulatory priorities. The Occupational Safety and Health Administration (OSHA) remains a central player in ensuring worker protection,...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

Husch Blackwell LLP

Trump Administration Clarifies Criminal Enforcement Priorities

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On May 9, 2025, the White House issued an executive order, titled “Fighting Overcriminalization in Federal Regulations,” that could have a significant impact on the administration’s enforcement of criminal regulatory...more

Health Care Compliance Association (HCCA)

Former OCR Director Fontes Rainer Reflects On ‘Imperfect’ RSP Law, Urges Final Security Reg

In October, the HHS Office for Civil Rights (OCR) fined Providence Medical Institute (PMI) $240,000, an amount that reflected a 20% discount for having “recognized security practices” (RSPs) in place. But many more covered...more

DLA Piper

FTC “Click-to-Cancel” Rule to Take Effect May 14

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In October 2024, the Federal Trade Commission (FTC) finalized significant updates to the Negative Option Rule, which are slated to take effect on May 14, 2025. A negative option is a contract term under which a buyer agrees...more

Stradling Yocca Carlson & Rauth

The SEC’s Enforcement Program Under President Trump’s Second Administration: What Can We Expect

Al Tierney, a partner in Stradling’s SEC enforcement practice, recently authored the article, “The SEC’s Enforcement Program Under President Trump’s Second Administration: What Can We Expect” for the OC Lawyer. With Paul...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

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

Bergeson & Campbell, P.C.

EPA Releases New TSCA and FIFRA Enforcement Policies

On January 17, 2025, days before the end of President Biden’s term, the U.S. Environmental Protection Agency (EPA) released two new enforcement documents: (1) Expedited Settlement Agreement (ESA) Pilot Program Under the...more

Cadwalader, Wickersham & Taft LLP

Regulation in Flux, March 2025 - Key Takeaways From CFTC Acting Chairman Caroline Pham’s FIA Boca 50 Keynote

On March 11, 2025 at the 50th Annual International Futures Industry (“FIA”) Conference, Commodity Futures Trading Commission (“CFTC”) Acting Chairman Caroline Pham delivered a ground-breaking keynote covering administrative...more

A&O Shearman

EU penalizes RPM and other vertical conduct violations

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The level of fines imposed for infringements relating to vertical and other non-cartel conduct increased ten-fold in 2024, reversing a trend of decline in recent years. This rise can be attributed in part to the overall...more

Cornerstone Research

SEC Accounting and Auditing Enforcement Activity Plummeted in Final Year of Gensler Administration

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The U.S. Securities and Exchange Commission (SEC) drastically reduced its accounting and auditing enforcement activity in fiscal year 2024, the final year of Gary Gensler’s administration, ending two consecutive years of...more

Whiteford

Client Alert: Mandatory CTA Compliance Returns – What You Need to Know

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On February 17, 2025, the U.S. District Court for the Eastern District of Texas lifted the last remaining nationwide injunction against enforcement of the Corporate Transparency Act (CTA) previously issued in Smith v. US...more

Latham & Watkins LLP

Treasury Finalizes Controversial Regulations on IRS Penalty Oversight, but Debate Continues

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Section 6751(b), designed to ensure supervisory oversight amid rising penalty assertions in settlement negotiations, has been contentious due its ambiguity, and the final regulations may not resolve the debate....more

Awatif Mohammad Shoqi Advocates & Legal...

Fresh Amendments to Law On Financial Audit Authority: Offending Employees Now Face Travel Ban and Asset Seizure

The Emirate of Dubai has recently passed new amendments to the existing “Dubai Law No. 4/2018 on the Establishment of the Financial Audit Authority” (“LAW”). As per the new amendments, financial fraud and misconduct in...more

Vinson & Elkins LLP

FERC Settles Decade-Old Enforcement Allegations

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In 2016, a new play called Hamilton was dominating Broadway, Pokémon Go was all the rage, and the Summer Olympics were held in Rio. Also that year, the Federal Energy Regulatory Commission (“Commission” or “FERC”) issued an...more

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