Enforcement

News & Analysis as of

Additional Recent Actions Added To UDAAP Database

The CFPB has issued new enforcement actions that include allegations of unfair, deceptive, or abusive acts and practices (UDAAP) in connection with consumer financial products. We’ve updated our UDAAP Database with the most...more

FCC Enforcement Advisory: Broadband Providers Must Take Reasonable, Good Faith Steps to Protect Consumer Privacy

On Wednesday, May 20, 2015, the FCC’s Enforcement Bureau issued its first enforcement advisory in the post-Open Internet Order era. Not surprisingly, the Bureau’s first advisory addressed the consumer privacy obligations of...more

Asset Management Firms And The Risk Of Market Abuse: Key Practical Points From The FCA's Thematic Review Feedback And Recent FCA...

Tackling market abuse continues to be a strategic priority for the FCA. In late 2014, the FCA undertook a thematic review into asset management firms and the risk of market abuse, the results of which were published in...more

Texas Supreme Court: Companies Shielded from Defamation Claims for Statements in Internal Investigation Reports

Last week, the Texas Supreme Court joined the majority of jurisdictions in holding that a company enjoys an absolute privilege when providing the Department of Justice (DOJ) with an internal investigation report containing...more

Africa Energy Update

The latest news on legal and regulatory developments in Africa's energy sector with perspectives from our offices in New York, Washington and London. This third Africa energy update focuses on North Africa, Africa's most...more

The Sixth Circuit Reins in the Government's Measure of False Claims Act Damages

Pharmaceutical and device companies, financial institutions, government contractors, oil and gas conglomerates, and other public and private entities continue to be in the crosshairs of aggressive federal government...more

FINRA’s Revised Sanction Guidelines: Higher, Tougher, Fairer?

FINRA’s newly revised Sanction Guidelines, effective immediately, signal that the upward trend in sanctions against broker-dealers is likely to continue. The Sanction Guidelines, which establish the range of sanctions...more

DOJ: Companies Need Not Expend Exorbitant Fees to Get Full Cooperation Credit

During an FCPA panel event, the Chief of the US Department of Justice’s Fraud Section advised companies to conduct “targeted” FCPA investigations, dismissing the suggestion that companies must spend hundreds of millions of...more

PHMSA Steps Up Review of Pipeline Construction

Enforcement Focus on 60-Day Notification Requirement - The Pipeline and Hazardous Materials Safety Administration (PHMSA) has stepped up enforcement efforts concerning pipeline and LNG terminal construction....more

What is the Current State of Anti-Bribery Compliance & Enforcement in Australia? [Video]

On March 13th, 2015, GRC Solutions hosted a Round-Table discussion with compliance and legal professionals from some of the largest firms in Australia. I was invited as an Anti-Bribery, Compliance and Ethics consultant via...more

[Webinar] Benchmarking Your Policy Management Program - May 21, 10:00am PT / 1:00pm ET

Join this free webinar to hear compelling survey results and answers to questions such as: What are organizations doing to address policy management today? What are E&C leaders’ top policy management...more

DOT Revises Its “Mistaken Fares” Enforcement Policy

DOT’s Office of Aviation Enforcement and Proceedings issued a notice temporarily amending its enforcement policy regarding airlines’ obligation to honor “mistaken fares.” Until now, DOT’s Enforcement Office has generally...more

Informed Compliance Period Comes to Its Imminent End for Importer Security Filing

CBP will be increasing enforcement of violations effective May 14, 2015. On May 14, the informed compliance period for Importer Security Filing (ISF) will come to an end and Customs and Border Protection (CBP) will...more

This Week In Securities Litigation

The debate over waivers WKSI waivers and other similar provisions continued this week. The Commission granted a WKSI waiver to Deutsche Bank despite a guilty plea to criminal felony charges but only over the dissent of...more

Wage and Hour Basics Series: Penalties for FLSA Non-Compliance

Periodically this year, we have discussed some of the fundamentals of wage and hour law, starting with a general review of the white collar exemptions. We will continue to periodically review some of the more fundamental...more

New Legislation Promises More Investigations by the New York City Commission on Human Rights

On April 20, 2015, New York City Mayor Bill de Blasio signed two new bills into law that authorize the New York City Commission on Human Rights to increase the number of employment discrimination investigations. ...more

CFPB Remains Noncommittal Regarding Restrained Enforcement Period for TILA/RESPA Integrated Disclosures Rule

The TILA/RESPA integrated disclosures (TRID) rule issued by the Consumer Financial Protection Bureau (CFPB) under the Dodd-Frank Wall Street Reform and Consumer Protection Act takes effect on August 1, 2015. ...more

Corinthian Colleges: Part Two - the "Perfect Storm" - Blog: Consumer Financial Protection Bureau

Corinthian Colleges (“Corinthian”) announced this past Sunday, April 26 that Corinthian was ceasing operations at its remaining physical campuses. This April 26 announcement specifically refers to the remaining 30 or so...more

Antitrust Enforcers Discuss Recent Highlights, Ongoing Cases, Enforcement Priorities and General Trends at the 2015 ABA Section of...

The American Bar Association (ABA) Section of Antitrust Law Spring Meeting concluded earlier this month with the traditional “Enforcers’ Roundtable,” an interview with leading competition authorities about recent highlights,...more

Financial Services Weekly News Roundup - April 2015 #5

Ninth Circuit Denies Rehearing of Northstar v. Schwab. On April 28, the U.S. Court of Appeals for the Ninth Circuit denied the petition of Schwab Investments’ (Schwab) for rehearing and rehearing en banc in the case of...more

Health Care Enforcement: The Impact on Private Equity Investments [Video]

Brian Platton provides an overview of enforcement trends that private equity investors should be aware of before entering into the health care space....more

DOJ Criminal Division Chief Provides Guidance on Corporate Charging Decisions

On April 17, 2015, Assistant Attorney General Leslie Caldwell provided helpful guidance regarding the Justice Department’s approach to corporate charging decisions in remarks that she delivered at New York University Law...more

Dealing with high-risk clients and final advice for maintaining an effective AML compliance program

Dealing with high-risk clients in an era of enhanced AML enforcement - To identify and trace criminal activity, federal law enforcement relies on the mandatory filing of suspicious activity reports (SARs) by financial...more

Section 337’s Potential for Defending Biologics Market Share Against Biosimilars

Enforcement of biologic patents at the United States International Trade Commission under Section 337 provides certainty and tactical advantages to patent holders that are unavailable in district court under the BPCIA. For...more

China Ripe For Enforcing AML Based On Concerted Action

So far in China there have not been any published decisions regarding price-fixing or other anti-competitive agreements based on concerted action by competitors. There is also no Chinese legal precedent for including...more

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