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DOJ National Security Division Issues Second Declination Since Issuance of Revised Corporate Enforcement Policy

On April 30, 2025, the National Security Division (NSD) of the Department of Justice (DOJ) announced the declination of prosecution against the Universities Space Research Association (USRA), a federal government contractor,...more

DOJ Releases New Key Guidance on Its Data Security Program (DSP)

On April 11, 2025, the National Security Division (NSD) of the Department of Justice issued a press release (Press Release) that outlines its approach to implementing and enforcing the DOJ’s recent final rule on “Preventing...more

Heightened False Claims Act Enforcement of Customs and Trade Violations

As the Trump administration forges ahead with its trade agenda, including almost weekly new tariffs, and antidumping and countervailing duties orders, heightened False Claims Act (FCA) enforcement is sure to follow. Below, we...more

DOJ’s Aggressive Efforts to Investigate a Federal Government Contractor

On February 18, 2025, Denise Cheung, leader of the criminal division at the U.S. Attorney’s Office for the District of Columbia, abruptly resigned. Prior to her resignation, Cheung had been at the Department of Justice (DOJ)...more

The Department of Justice’s Policy Changes — Key Takeaways for the Business Community

Over the past few days, the Department of Justice (DOJ) has issued several significant policy memos that reshape the landscape for corporate legal risk, particularly for multinational corporations engaged in international...more

New York Department of Financial Services Levies $1.2 Million Fine on Cryptocurrency Platform for Violations of Cybersecurity...

A recent consent order between the New York State Department of Financial Services (“NYDFS”) and cryptocurrency trading platform, bitFlyer USA (“bitFlyer”), shows that the NYDFS continues to utilize an aggressive enforcement...more

New York Department of Financial Services Announces $5 Million Penalty in Most Recent Cybersecurity Enforcement Action

On June 23, 2022, the New York State Department of Financial Services (NYDFS) announced the entry of a Consent Order in connection with its most recent cybersecurity enforcement action, which included a $5 million monetary...more

FBI Announces Increased Focus on Illegal Financial Transactions Involving Cryptocurrency

Cryptocurrency has increasingly become an accepted form of financial exchange. However, it has also become a favored form of payment for cyber criminals. In an effort to deter the use of cryptocurrencies in furtherance of...more

Fall Cybersecurity Enforcement Update: State and Federal Regulators Increase Scrutiny on Victims of Cyberattacks

We have written here previously about the dramatic increase in cyberattacks on companies of all types since the start of the COVID-19 pandemic. Indeed, by some estimates, ransomware attacks have increased over 90% during the...more

New York Department of Financial Services and National Securities Corporation Agree to $3 Million Settlement in Cybersecurity...

Earlier this month, the New York State Department of Financial Services (NYDFS) announced a settlement and consent order with National Securities Corporation (National Securities) for $3 million in connection with National...more

New York Department of Financial Services Announces $1.5 Million Settlement of Second Cybersecurity Enforcement Action

On March 3, 2021, the New York State Department of Financial Services (NYDFS) announced a settlement with Residential Mortgage Services, Inc. (RMS) for $1.5 million in connection with its violation of the NYDFS Cybersecurity...more

Predicting the Enforcement Priorities of the Biden DOJ

With President Biden’s nomination of D.C. Circuit Judge Merrick Garland for U.S. attorney general proceeding toward confirmation in the Senate, the leader of the nation’s legal department is poised to change enforcement...more

The U.S. Department of Justice Releases its Cryptocurrency Enforcement Framework

Earlier this year, the U.S. Department of Justice (“DOJ”) released its highly anticipated Cryptocurrency Enforcement Framework (the “Framework”).  The Framework was developed as part of the Attorney General’s Cyber-Digital...more

CFTC Enforcement Division Reports Most Active Year to Date

On December 1, 2020, the U.S. Commodity Futures Trading Commission (“CFTC”) Division of Enforcement released its Annual Report, which details a “record-breaking” fiscal year 2020 (“FY 2020”), despite the challenges presented...more

SEC Settles Enforcement Action against Private Equity Firm for Beneficial Ownership Reporting Violations

On September 17, 2020, the SEC announced the imposition of a cease-and-desist order against private equity firm Welsh, Carson, Anderson & Stowe (Welsh Carson), an SEC-registered investment manager, in connection with alleged...more

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