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State Department Partners With Education Department on Section 117 Foreign Gift and Contract Reporting

On Feb. 23, 2026, the U.S. Department of Education (the Department) announced a new interagency partnership with the U.S. Department of State (State Department) to share responsibilities for oversight of Section 117 of the...more

OFAC Enforcement Action Against Academic Institution Provides Important Compliance Guidance

On February 12, 2026, Treasury’s Office of Foreign Assets Control (OFAC) announced the settlement of an enforcement action against IMG Academy (“IMG”) that highlighted the sanctions risks that U.S. academic institutions face...more

Creation of DOJ Fraud Division Signals Increased White-Collar Enforcement

On January 8, 2026, the White House announced the establishment of a new division of the Department of Justice: The Division for National Fraud Enforcement. In a White House Fact Sheet, the Trump Administration stated that...more

Renewed Scrutiny: Intensified Oversight of Foreign Gifts, Contracts and Ties in U.S. Higher Education

The Trump administration is placing increased emphasis on oversight of foreign gifts, contracts and connections with colleges and universities in the United States. Newly announced reporting mechanisms and statutory changes...more

Commerce Department Launches Section 232 Tariff Investigation on Wind Turbines

The U.S. Department of Commerce initiated an investigation into how wind turbines and related components may impact U.S. national security on Aug. 13, 2025, according to an Aug. 21, 2025, notice sent to the Federal Register....more

After a Pause, DOJ’s Updated FCPA Guidelines Focus on Cartels and TCOs, But Corporate Exposure Remains

On June 9, Deputy Attorney General Todd Blanche issued a memorandum to the Department of Justice’s Criminal Division, outlining the Department’s focus for pending and future FCPA actions. ...more

Justice Department Issues First Declination Under NSD’s M&A Safe Harbor Policy to Private Equity Firm, Reinforcing Roadmap for...

On June 16, the U.S. Department of Justice’s (DOJ) National Security Division (NSD) and the U.S. Attorney’s Office for the Southern District of Texas (USAO-SDTX) announced their decision to decline prosecution of White Deer...more

Federal Court Strikes Down Two Key Tariffs, Appeal Pending

On May 28, 2025, the U.S. Court of International Trade declared key tariffs implemented by the Trump administration under the International Emergency Economic Powers Act (IEEPA) unconstitutional. The ruling directly impacts...more

U.S. and China Move to Lower Tariffs, Relieve Supply Chain Pressures, Costs for Businesses

The United States and the Republic of China announced a significant step toward easing longstanding trade tensions, with both nations agreeing to lower a series of tariffs imposed during the ongoing trade dispute. The...more

Practical Tips for Companies Following President Trump’s Pause on FCPA Enforcement

Since the President signed the February 10, 2025 Executive Order (Order) pausing enforcement of the Foreign Corrupt Practices Act (FCPA) (Client Alert: President Trump issues Executive Order “Pausing Foreign Corrupt Practices...more

Major Shift on Foreign Corrupt Practices Act: Trump Signs EO Pausing Enforcement

Last night, in a move with wide-ranging implications for American companies doing business abroad, President Trump issued an executive order (Order) temporarily halting enforcement of the Foreign Corrupt Practices Act (FCPA)....more

State Attorneys General Poised to Crack Down On Price Gouging Amid Market Pressure

This past Thursday, New York Attorney General Letitia James issued a warning to businesses against price gouging for eggs and poultry. The current bird flu outbreak began in March 2024 but has become a topic of increasing...more

Trump Tariffs on Canada, Mexico, and China

On February 1, 2025, the Trump Administration imposed long-expected tariffs on imports from Canada, Mexico, and China through the issuance of three executive orders (“EOs”). While some recent reporting suggested that...more

Trump Administration Tariff Regime: Uncertainty and Expectations

As he enters his second week in office, President Donald Trump is forecasting a desire to implement a muscular trade policy leaning heavily on the imposition of tariffs—potentially on a global basis—as a means of extracting...more

OFAC Enforcement Action Targets Non-U.S. Business Purchasing Services From North Korean Firm

On June 26, Treasury’s Office of Foreign Assets Control (OFAC) announced the settlement of an enforcement action against an Italian animation company that violated OFAC’s sanctions on North Korea. The enforcement action...more

Disruptive Technology Strike Force Announces Its First Declination to Prosecute Under the National Security Division’s Voluntary...

On May 22, 2024, the Department of Justice’s National Security Division (“NSD”) announced its first declination of prosecution for a company under the voluntary self-disclosure program established by the National Security...more

G7+ Coalition Issues Alert on Russian Oil Price Cap Evasion Methods and How to Report Violations

On February 1, 2024, the G7+ Coalition (consisting of the G7, the European Union, and Australia) published an Oil Price Cap (OPC) Compliance and Enforcement Alert (the “Alert”), identifying notable OPC evasion methods and...more

Disruptive Technology Strike Force Continues Focus on Trade Secret Theft, Export Control Enforcement

The Disruptive Technology Strike Force hosted a summit on Feb. 7-8, 2024, in Phoenix, Arizona, to commemorate its one-year anniversary. The Strike Force is an interagency law enforcement effort aimed at preventing...more

BIS Continues Enforcement Policy Ramp-Up

On January 16, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance to incentivize voluntary self-disclosure (“VSD”) of possible violations of the Export Administration...more

Recent Sanctions Enforcement Actions Demonstrate Importance of  Incorporating All Available Data into Screening

For U.S. businesses, sanctions compliance has never been more challenging or more important. The U.S. has responded to Russia’s invasion of Ukraine with a broad range of sanctions targeting the Russian government, its...more

California Climate Accountability Package Poised to Disrupt

During the week of September 11, 2023, the California Legislature passed a series of bills known collectively as the “California Climate Accountability Package” (“CCAP”). The CCAP is comprised of three bills: S.B. 252...more

Departments of Justice, Commerce and Treasury Issue Tri-Seal Compliance Note on Voluntary Self-Disclosure of Potential Violations

On July 26, 2023, the U.S. Department of Justice’s National Security Division, U.S. Department of Commerce’s Bureau of Industry and Security, and U.S. Department of the Treasury’s Office of Foreign Assets Control issued a...more

Disruptive Technology Strike Force Initiates Federal Prosecutions Targeting Trade Secret Theft

In early 2023, the U.S. Department of Justice and U.S. Department of Commerce launched the Disruptive Technology Strike Force to target illicit actors, strengthen supply chains and protect critical technology assets from...more

U.S. Department of Justice and Partners Increasing Enforcement of Sanctions and Export Controls

It has been a little more than a year since Russia’s invasion of Ukraine, and the war continues to rage. In an effort to deter the Russian government and weaken its military capabilities, the United States has imposed...more

FinCEN Alert Highlights Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites and Their Proxies

The Financial Crimes Enforcement Network (FinCEN) has recently issued an alert cautioning all financial institutions regarding potential investments in the U.S. commercial real estate (CRE) sector, by or on behalf of...more

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