SEC Intensifies Oversight of Foreign Companies that Participate in U.S. Capital Markets
According to NERA, a leading consulting and expert firm, the share of foreign-based companies listed on U.S. stock exchanges has risen steadily in the last decade, from 17.4% in 2016 to 26.9% in 2025. As noted in our September 18 blog post, the U.S. Securities and Exchange Commission (SEC) recently […]
SEC Creates Cross-Border Task Force to Combat Fraud
On September 5, 2025, the U.S. Securities and Exchange Commission (SEC) announced the formation of a Cross-Border Task Force that will “strengthen and enhance the Division of Enforcement’s efforts to identify and combat cross-border fraud harming U.S. investors.” According to the SEC, the task force will “focus initially on investigating […]
Department of Justice Launches Cross-Agency Task Force to Combat Trade Fraud
On August 29, 2025, the US Department of Justice (DOJ) announced the formation of a cross-agency Trade Fraud Task Force to “identify and combat trade fraud that threatens [US] economic and national security interests.” According to DOJ, this partnership between its Civil and Criminal Divisions and the Department of Homeland […]
Sixth Circuit Shields Internal Investigation Materials From Discovery
In a closely watched case, the US Court of Appeals for the Sixth Circuit recently took a significant step to protect the attorney-client privilege over materials produced during internal investigations by companies. On August 7, 2025, the Sixth Circuit stayed a district court order compelling production of documents generated by […]
US DOJ Memo Clarifies DEI Compliance for Federal Funding Recipients
On July 30, 2025, US Attorney General Pam Bondi released a memo to all federal agencies titled “Guidance for Recipients of Federal Funding Regarding Unlawful Discrimination.” This document clarifies how federal antidiscrimination laws apply to programs or initiatives “that may involve discriminatory practices,” including diversity, equity and inclusion (DEI) initiatives. […]
‘Whole-of-Government Approach’ Targets Healthcare Fraud From Every Angle
Just months after the US Department of Justice (DOJ) designated healthcare fraud as one of its key criminal enforcement priorities, two recent announcements underscore the federal government’s continued focus on combating fraud of this kind. On July 2, DOJ announced a renewed partnership with the US Department of Health and […]
CFPB Announces Plan to Review Offenses Carrying Criminal Penalties
On June 27, the Consumer Financial Protection Bureau (CFPB) issued a policy statement, “Guidance on Referrals for Potential Criminal Enforcement,” which outlines its plan to address criminal regulatory offenses within its jurisdiction, as directed by President Donald Trump’s May 9, 2025, Executive Order (EO)14294, “Fighting Overcriminalization in Federal Regulations.” EO […]
First-Ever Sentencing of Corporate Executives for Failure to Report Under Consumer Product Safety Act
As we previously reported, in November 2023, two corporate executives were convicted of conspiracy and failure to report defective dehumidifiers in violation of the Consumer Product Safety Act (CPSA). This groundbreaking prosecution was the first-ever criminal conviction of corporate executives for failure to report under the CPSA. On June 16, […]
DOJ Resumes Foreign Bribery Investigations, Focusing on ‘Vindication of US Interests’
On June 9, 2025, the Department of Justice (DOJ) issued new guidelines for investigations and enforcement of the Foreign Corrupt Practices Act (FCPA), following a four-month pause of new FCPA investigations per President Donald Trump’s February 10 executive order. The new guidelines provide a nonexhaustive list of factors for prosecutors […]
DOJ Announces Priorities and Policy Updates – Including Tariff Compliance Enforcement, Expansion of Whistleblower Program
Over the last year, we have paid close attention to the increasingly complicated and evolving landscape companies are facing in light of changing government enforcement priorities, including the Department of Justice’s (DOJ’s) focus on tariff compliance and its pilot program to reward whistleblowers who report corporate wrongdoing to the government. […]