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CFTC Releases Criteria for Operating Divisions to Refer Violations to Enforcement Division

On April 17, 2025, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division (MPD), the Division of Clearing and Risk (DCR), and the Division of Market Oversight (DMO)—collectively the Operating...more

Acting CFTC Chairman Caroline D. Pham Releases Additional Enforcement Guidance

On March 11, acting Commodity Futures Trading Commission (CFTC) Chairman Caroline D. Pham offered insight into the regulator’s February 25, 2025 advisory in a keynote addressed delivered at Boca, the annual International...more

CFTC Enforcement Division Releases Mitigation Credit Matrix for Self-Reporting, Cooperation, and Remediation

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

False Claims Act Insights - Is DOJ Allowed to Share Privileged Documents with Whistleblowers in FCA Disputes? [Video]

Host Jonathan Porter welcomes Husch Blackwell partner Kip Randall back to the program to dig deeper into Omni Healthcare, Inc. et al v. MD Spine Solutions LLC et al., a False Claims Act litigation in which the defendant...more

False Claims Act Insights - If Everything Matters, Nothing Does: Parsing Materiality in FCA Disputes [Audio]

Host Jonathan Porter welcomes Husch Blackwell attorney Kip Randall to the podcast to discuss the beguiling notion of materiality in the context of False Claims Act litigation. Kip and Jonathan draw from case law to illustrate...more

DOJ Updates FCPA Corporate Enforcement Policy

On January 17, 2023, Assistant Attorney General (AAG) Kenneth Polite, Jr. announced updates to the Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy. Since the inception of the FCPA Corporate Enforcement...more

DOJ Updates Its Evaluation Of Corporate Compliance Programs

On June 1, 2020, the U.S. Department of Justice (DOJ) Criminal Division updated its Evaluation of Corporate Compliance Programs (the Evaluation Guidance). The Evaluation Guidance directs federal prosecutors to consider the...more

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