News & Analysis as of

Administrative Consent Order (ACO)

Troutman Pepper Locke

Another Alternative Retail Electric Supplier Enforcement Action Settles in Illinois

Troutman Pepper Locke on

On June 4, 2026, Illinois Attorney General (AG) Kwame Raoul announced a settlement with Rushmore Energy, LLC (Rushmore), resolving allegations that the company violated the Illinois Consumer Fraud and Deceptive Business...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Wastewater Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Wood Product...

The Arkansas Department of Energy and Environment, Division of Environmental Quality (“ADEQ”) and Custom Wood Recycling, Inc. (“CWR”) entered into a May 22nd Consent Administrative Order (“CAO”) addressing an alleged...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Wastewater Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Marion Travel Center...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“ADEQ”) and New Five Star Enterprise LLC (“Five Star”) entered into an April 16th Consent Administrative Order (“CAO”) addressing an...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and East Camden Missile...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“ADEQ”) and Lockheed Martin Corporation (“LMC”) entered into a May 22nd Consent Administrative Order (“CAO”) addressing an alleged...more

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Air Enforcement: U.S. Environmental Protection Agency and Reeves County, Texas Saltwater Disposal Facility Operator Enter into...

The United States Environmental Protection Agency (“EPA”) and WES Water Holdings, LLC (“WES”) entered into a May 14th Consent Agreement (“CA”) alleging violations of Clean Air Act regulations. See Docket NO. CAA-06-2026-3303....more

Sullivan & Worcester

The End of the Road for the SEC’s Administrative Order “No-Deny” Rule

Sullivan & Worcester on

The SEC has rescinded, effective immediately, its long-standing policy requiring a defendant or respondent, as a condition to settlement of an administrative proceeding, to agree not to publicly deny the allegations set forth...more

Orrick, Herrington & Sutcliffe LLP

Texas regulator fines payroll processor, surrogacy escrow provider for alleged unlicensed money transmission

Recently, the Texas Department of Banking (DOB) issued two separate consent orders against companies for alleged unlicensed money transmission under Texas Finance Code Chapter 152, assessing a $75,000 penalty against a...more

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Stormwater Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Faulkner County...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“ADEQ”) and JJR Construction, LLC (“JJR”) entered into a February 19th Consent Administrative Order (“CAO”) addressing alleged violations...more

Baker Donelson

FTC Puts Non-Competes Back in its Crosshairs and Raises the Stakes for Employer Non-Compete Practices

Baker Donelson on

The Federal Trade Commission's (FTC) recent action against a nationwide extermination company is less about pest control and more about how aggressively the agency plans to scrutinize non-compete agreements moving forward....more

Mogin Law LLP

FTC Shows Utility of Antitrust Actions for Smaller Companies in Niche Markets

Mogin Law LLP on

The Federal Trade Commission’s May 1, 2026 consent order involving “micromarket kiosk” companies illustrates how the agency is applying modern merger enforcement principles beyond the big technology platforms that typically...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Wastewater Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and City of Monette...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“ADEQ”) and City of Monette, Arkansas entered into a March 19th Consent Administrative Order (“CAO”) addressing an alleged violation of a...more

Orrick, Herrington & Sutcliffe LLP

FDIC publishes March enforcement actions

On April 24, the FDIC published a list of administrative and enforcement actions taken in March. The FDIC issued 22 orders, consisting of one consent order, seven orders terminating consent orders, two orders to pay civil...more

Orrick, Herrington & Sutcliffe LLP

Connecticut fines mortgage lead generator $50K for alleged unlicensed operations

On March 26, the Connecticut Banking Department issued a consent order against a lead generation company for operating as a mortgage lead generator in the state without the required license from at least February 2020 to...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Monticello Polystyrene Foam...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“ADEQ”) and Drew Foam Companies Inc. (“DF”) entered into a January 30th Consent Administrative Order (“CAO”) addressing an alleged...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Fort Smith Industrial Sand...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“ADEQ”) and Covia ISP, Inc. (“Covia”) entered into a March 11th Consent Administrative Order (“CAO”) addressing an alleged violation of a...more

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Wastewater Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Craighead County...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“ADEQ”) and Westside Consolidated School District #5 (“Westside”) entered into a January 16th Consent Administrative Order (“CAO”)...more

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Air Enforcement: Arkansas Department of Energy and Environment -Division of Environmental Quality and Bono Petroleum Storage Tank...

The Arkansas Department of Energy and Environment -Division of Environmental Quality (“ADEQ”) and Murphy Oil USA, Inc. (“Murphy Oil”) entered into a December 9th Consent Administrative Order (“CAO”) addressing a violation of...more

Sheppard

Washington DFI Enters Consent Order with Digital Assets-Focused Money Transmitter

Sheppard on

On February 9, 2026, the Washington State Department of Financial Institutions (DFI) entered into a consent order with a digital assets-focused money transmitter requiring the company to cease and desist from violating...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Blytheville Graphite...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“ADEQ”) and Mid-Continent Coal and Coke Company (“MC”) entered into a February 19th Consent Administrative Orrder (“CAO”) addressing an...more

Orrick, Herrington & Sutcliffe LLP

Washington state enters $150K consent order with digital assets-focused money transmitter

On February 9, the state of Washington’s Department of Financial Institutions (DFI) issued a consent order requiring a digital assets-focused money transmitter to cease and desist from violating the state’s Uniform Money...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Wastewater Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and City of Garland...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“ADEQ”) and the City of Garland, Arkansas (“Garland”) entered into a January 9th Consent Administrative Order (“CAO”) addressing alleged...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Wastewater Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Sparkman Lumber...

The Arkansas Department of Energy and Environment, Division of Environmental Quality (“DEQ”) and Ray White Lumber Company (“RWLC”) entered into a January 30th Consent Administrative Order (“CAO”) addressing alleged violations...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Missouri Department of Natural Resources and Perryville Auto Parts Manufacturer Enter into Administrative Order...

The Missouri Department of Natural Resources (“MDNR”) and TG Missouri Corporation (“TG”) entered into a January 8th Administrative Order on Consent (“AOC”) addressing an alleged violation of an Air Permit. See No....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Waste Tire Enforcement: Mississippi Commission on Environmental Quality and Jackson Waste Tire Stockpile Owner Enter into Agreed...

The Mississippi Commission on Environmental Quality (“MCEQ”) and Vemoci, LLC (“Vemoci”) entered into a January 8th Agreed Consent Order (“ACO”) addressing issues associated with a waste tire pile. See Order No. 7533 25....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Missouri Department of Natural Resources and Raytown Gasoline Dispensing Facility Enter into Administrative Order...

The Missouri Department of Natural Resources (“MDNR”) and PAK American, L.L.C. d/b/a PAK American Shell (“PAK”) entered into a December 30, 2025 Administrative Order on Consent (“AOC”) addressing an alleged violation of the...more

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