On July 21, 2025, in Commodity Futures Trading Commission et al. v. TMTE Inc et al., a Texas district court denied summary judgment to both the Commodity Futures Trading Commission (CFTC) and two individual defendants in a...more
8/13/2025
/ CFTC ,
Commodity Exchange Act (CEA) ,
Corporate Counsel ,
Dodd-Frank ,
Enforcement Actions ,
Financial Markets ,
Fraud ,
Futures ,
Gold ,
Jurisdiction ,
Metals ,
Motion for Summary Judgment ,
Regulatory Authority ,
State Attorneys General ,
Statutory Interpretation
In March 2025, in a similar blog post to this one, Nithya Nagarajan and Robert Romashko forecasted that False Claims Act (“FCA”) enforcement would increase under the current tariff-focused trade policy regime. Sure enough,...more
8/13/2025
/ Anti-Dumping Duty ,
Compliance ,
Corporate Counsel ,
Countervailing Duties ,
Customs ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Imports ,
International Trade ,
Tariffs ,
Trade Policy ,
Whistleblowers
In June 2025, the Department of Justice (DOJ) announced its 2025 National Health Care Fraud Takedown, marking the largest coordinated healthcare fraud enforcement action in DOJ history. The sweep included charges against a...more
8/8/2025
/ Controlled Substances ,
Criminal Prosecution ,
DEA ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
FBI ,
Genetic Testing ,
Health Care Providers ,
Healthcare Fraud ,
Medicaid ,
Medicare ,
Popular ,
Prescription Drugs ,
Telemedicine ,
Virus Testing
Last year, the Department of Justice (DOJ) National Security Division (NSD) updated its Enforcement Policy for Business Organizations to include guidance related to voluntary self-disclosures in connection with acquisitions....more
7/30/2025
/ Acquisitions ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Due Diligence ,
Economic Sanctions ,
Enforcement ,
Enforcement Actions ,
Export Controls ,
National Security ,
Portfolio Companies ,
Private Equity ,
Sanctions ,
Self-Disclosure Requirements ,
White Collar Crimes
On July 9, 2025, the Commodity Futures Trading Commission (CFTC) Division of Enforcement (DOE), acting pursuant to a recent executive order (EO), issued an advisory letter outlining its new policy for referring criminally...more
7/21/2025
/ Advisory Opinions ,
CFTC ,
Compliance ,
Criminal Liability ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
Enforcement Authority ,
Executive Orders ,
Financial Markets ,
Financial Services Industry ,
Penalties ,
Regulatory Reform ,
Regulatory Requirements ,
White Collar Crimes
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
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
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
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
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
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
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