On April 17, 2025, three operating divisions (the “Operating Divisions”) of the U.S. Commodity Futures Trading Commission (“CFTC”) and the Division of Enforcement (“DOE”) provided guidance in CFTC Letter 25-13 (the...more
4/29/2025
/ CFTC ,
Disclosure Requirements ,
Enforcement Actions ,
Financial Crimes ,
Materiality ,
New Guidance ,
Penalties ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management ,
Self-Reporting
Designed for busy in-house counsel and compliance professionals, this newsletter seeks to bring you up to speed on key federal and state False Claims Act (FCA) developments, with links to primary resources. Each quarter,...more
The Advisory sets out factors that the Enforcement Division will use to rate self-reporting and cooperation. This rating places a company or individual within a “tier” used to determine the Mitigation Credit amount available....more
The New York Attorney General (NYAG) is expected to increase enforcement actions in 2025, especially with the enactment of several new laws designed to strengthen consumer protection and employment. At the federal level, the...more
2/25/2025
/ Antitrust Provisions ,
Climate Change ,
Consumer Protection Laws ,
Cryptocurrency ,
Cybersecurity ,
Enforcement Actions ,
Environmental Policies ,
Greenwashing ,
Popular ,
Privacy Laws ,
State Attorneys General
Designed for busy in-house counsel and compliance professionals, this newsletter seeks to bring you up to speed on key federal and state False Claims Act (FCA) developments, with links to primary resources. Each quarter, we...more
1/28/2025
/ Anti-Kickback Statute ,
Appointments Clause ,
Article II ,
Books & Records ,
CVS ,
Cybersecurity ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Billing ,
False Claims Act (FCA) ,
Genetic Testing ,
Healthcare Fraud ,
Medicare ,
OIG ,
Patient Referrals ,
Qui Tam ,
State and Local Government ,
State Attorneys General ,
Walgreens ,
Whistleblowers
On January 17, 2023, the Assistant Attorney General (AAG) for the Criminal Division of the U.S. Department of Justice (DOJ), Kenneth Polite, Jr., announced that DOJ had made “significant changes” to its Corporate Enforcement...more
The U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have recently intensified their scrutiny of insider trading under Rule 10b5-1 trading plans. The emerging trend of enforcement investigations...more
11/9/2022
/ CFTC ,
Chief Technology Officer (CTO) ,
Cooling-Off Rule ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Insider Trading ,
MNPI ,
Proposed Amendments ,
Rule 10b-5 ,
Securities and Exchange Commission (SEC)
On August 9, 2022, in CFTC v. EOX Holdings LLC, the first insider trading trial in a Commodity Futures Trading Commission (CFTC) enforcement action, a jury in the U.S. District Court for the Southern District of Texas found...more
Morrison & Foerster’s Automotive Task Force represents automotive industry clients in their most significant legal matters.
We have tapped our multidisciplinary Automotive Task Force to get their opinions on what is likely...more
2/23/2022
/ Anti-Bribery ,
Antitrust Division ,
Automotive Industry ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Initial Public Offering (IPO) ,
International Trade Commission (ITC) ,
Popular ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Special Purpose Acquisition Companies (SPACs)
The Department of Justice (“DOJ” or “Department”) has continued to make clear that white collar crime is a top priority of its enforcement efforts. On October 28, 2021, Deputy Attorney General (“DAG”) Lisa Monaco issued a...more
In a keynote address at the Global Investigations Review Connect: New York conference on October 5, Principal Associate Deputy Attorney General John Carlin provided insights into future Department of Justice (“DOJ” or the...more
10/15/2021
/ Cryptocurrency ,
Department of Justice (DOJ) ,
DPA ,
Enforcement Actions ,
Export Controls ,
ITAR ,
Military Service Members ,
National Security ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Sanctions ,
Self-Disclosure Requirements ,
United Arab Emirates (UAE) ,
US Department of State ,
Virtual Currency
“Decentralization” is a concept that has consistently vexed the entire blockchain-enabled ecosystem in the U.S., including its counsel and regulators, wherein a lack of clarity on the exact definition of decentralization has...more
4/22/2021
/ Bitcoin ,
Blockchain ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
Howey ,
Information Commissioner's Office (ICO) ,
Investment Contract ,
Popular ,
Securities and Exchange Commission (SEC)