News & Analysis as of

Risk Management Civil Monetary Penalty

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

112(r)/Air Enforcement: U.S. Environmental Protection Agency and City of Dallas, Oregon Wastewater Treatment Plant Enter into...

The United States Environmental Protection Agency (“EPA”) and City of Dallas, Oregon entered into a July 25th Expedited Settlement Agreement (“ESA”) addressing an alleged violation of the Clean Air Act. See DOCKET NO....more

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

Jenner & Block on

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

DLA Piper on

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

Husch Blackwell LLP on

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

Saul Ewing LLP

Seeing is Believing: A Civil Money Penalty With Warby Parker Following Cybersecurity Incident

Saul Ewing LLP on

On February 20, 2025, the U.S. Department of Health and Human Services (HHS), Office for Civil Rights (OCR) announced a $1.5 million civil money penalty (CMP) against Warby Parker, Inc. (WP). WP is a manufacturer and online...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

The Volkov Law Group on

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

The Volkov Law Group on

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

BCLP on

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

Jackson Lewis P.C.

Florida Healthcare Provider Faces $1.19M HIPAA Penalty Following Independent Contractor Breach

Jackson Lewis P.C. on

A healthcare provider delivering pain management services in Florida and other states faces a $1.19 million civil monetary penalty from the U.S. Department of Health and Human Services (HHS), Office for Civil Rights (OCR)....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

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

12(r)/Air Enforcement: U.S. Environmental Protection Agency and Henderson, Iowa Grain Facility Enter into Expedited Settlement...

The United States Environmental Protection Agency (“EPA”) and Hartland Co-op (“Heartland”) entered into an August 5th Expedited Settlement Agreement (“ESA”) addressing alleged violations of the Clean Air Act Risk Management...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

Health Care Compliance Association (HCCA)

Due diligence and physician financial arrangements

Conducting due diligence for physician and provider compensation arrangements during a healthcare transaction is critical for the acquirer. Appropriate due diligence is necessary, regardless of whether the transaction is a...more

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

112(r)/Air Enforcement: U.S. Environmental Protection Agency and Downington Town, Pennsylvania, Water Authority Enter into...

The United States Environmental Protection Agency (“EPA”) and Downington Regional Water Authority (“DRWA”) entered into an Expedited Settlement Agreement (“ESA”) addressing alleged violations of Section 112(r) of the Clean...more

Bass, Berry & Sims PLC

Recap of Webinar: Billing, Coding, and Collecting for Infusion Services

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Bass, Berry & Sims attorney Shannon Wiley, with Carine Leslie and Katie Garmon of PYA, P.C., recently discussed the complexities associated with billing, coding, and collecting for infusion services as part of the Infusion...more

Foley & Lardner LLP

HIPAA Breaches and Compliance: Key Findings & Lessons Learned from OCR’s Reports to Congress

Foley & Lardner LLP on

The Office of Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) recently submitted two annual reports to Congress setting forth a summary of complaints and breaches reported to the OCR during...more

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