News & Analysis as of

Consent Order

Alston & Bird

FTC Reverses Rytr Consent Order Amid Push for Federal AI Standards

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On December 22, 2025, the Federal Trade Commission (FTC) set aside its 2024 consent order against Rytr, a generative AI-powered company, concluding that the original complaint “failed to satisfy the legal requirements of the...more

Kelley Drye & Warren LLP

Ad Law News and Views - January 2026

While much of the country was bundled up in cold winter weather, privacy leaders and regulators braved the icy roads and gathered in our DC office earlier this week for our Privacy State of the Union event....more

Sheppard Mullin Richter & Hampton LLP

DFPI Imposes Up to $1 Million Penalty on Crypto Kiosk Operator for Alleged Digital Financial Assets Law Violation

On January 16, the DFPI entered into a consent order with a digital financial asset kiosk operator, based on DFPI’s allegations that the operator violated the Digital Financial Assets Law (DFAL), the California Consumer...more

Sheppard Mullin Richter & Hampton LLP

DFPI Orders Mortgage Lender to Pay $160,000 for Alleged Unlicensed Mortgage Loan Originator Activity

On December 31, the DFPI entered into a consent order with a residential mortgage lender to resolve allegations of unlicensed mortgage loan origination activity under the California Financing Law and the California...more

White & Case LLP

Crypto company hit with $500,000 penalty by California regulator

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On January 14, 2026, the California Department of Financial Protection and Innovation announced an enforcement action and $500,000 penalty against crypto platform Nexo Capital Inc. for violating California's lender licensing...more

Orrick, Herrington & Sutcliffe LLP

California DFPI orders digital asset kiosk operator to pay $277K+ in restitution and penalties

On January 13, the California DFPI entered a consent order with a digital financial asset kiosk operator to stop accepting transactions greater than $1,000 from a customer with the same name in a single day (in violation of...more

Orrick, Herrington & Sutcliffe LLP

California DFPI orders mortgage firm to pay $160K penalty and undergo audit

Recently, the California DFPI entered a consent order resolving allegations of unlicensed mortgage loan origination activity at a California branch of a Texas-based mortgage company. ...more

Orrick, Herrington & Sutcliffe LLP

California DFPI issues $1M consent order against digital asset kiosk operator

On January 16, after identifying repeated violations of the Digital Financial Assets Law (DFAL) and the California Consumer Financial Protection Law (CCFPL), the California DFPI entered a consent order requiring a digital...more

Sheppard Mullin Richter & Hampton LLP

DFPI Orders Crypto Lending Platform to Pay $500,000 for Alleged Unlicensed Lending and Underwriting Failures

On January 14, the DFPI announced a consent order requiring a crypto lending platform to pay $500,000 in penalties for alleged violations of the California Financing Law and the California Consumer Financial Protection Law....more

Troutman Pepper Locke

Kim Kardashian’s Clothing Company Settles With New Jersey AG After Collecting Sales Tax on Tax-Exempt Items

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On his last day in office, New Jersey Attorney General (AG) Matt Platkin announced a consent order resolving a consumer fraud investigation into Skims Body, Inc. for charging consumers in New Jersey sales tax on items that...more

Hudson Cook, LLP

CFS Bites of the Month - 2025 Annual Review - Business to Business

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In this article, we share a timeline of monthly "bites" for 2025 applicable to business transactions....more

Hudson Cook, LLP

CFS Bites of the Month - 2025 Annual Review - Payments

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In this article, we share a timeline of monthly "bites" for the past year applicable to Payments....more

Ballard Spahr LLP

CFPB Blasts Former Bureau Leadership For ‘Regulatory Overreach’

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The CFPB, under former Director Rohit Chopra, regularly engaged in regulatory overreach, the Bureau’s current leadership said in its semi-annual report, covering the period from April 1- September 30, 2024. “As indicated...more

Fox Rothschild LLP

When “Too Good To Be True” Really Is Too Good To Be True: FTC Settles With NextMed Regarding Deceptive Advertising Practices.

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The Federal Trade Commission (“FTC”) has reached a settlement with NextMed (also known as Southern Health Solutions, Inc.), resolving allegations that the telehealth company misled consumers through deceptive advertising,...more

Ballard Spahr LLP

FinCEN Imposes $3.5 Million Civil Penalty Against Paxful for BSA Violations

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In December, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a $3,500,000 civil penalty against Paxful, Inc. and Paxful USA, Inc. (“Paxful”), pursuant to a consent order. Paxful is an...more

Hudson Cook, LLP

CFS Bites of the Month - 2025 Annual Review - Mortgage

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In this article, we share a timeline of monthly "bites" for the past year applicable to Mortgage....more

Troutman Pepper Locke

FTC Announces Settlement With Crypto Firm Over Exploited Security Vulnerability

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The Federal Trade Commission (FTC) announced a proposed consent order with Illusory Systems Inc. (Illusory), a Utah-based blockchain infrastructure company that operates the Nomad Token Bridge. The settlement resolves the...more

Hinch Newman LLP

Restrictions Imposed on Use of FTC “Means and Instrumentalities” Liability

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The Federal Trade Commission utilizes a number of remedial theories when attempting to hold a bad actor liable for the actions of a third party. One such theory is known as “means and instrumentalities” liability, where a...more

Roetzel & Andress

Understanding the IDFPR Investigation and Complaint Process: The Basics for Health Care Providers

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Have you received a call from an investigator or prosecutor at the Illinois Department of Financial and Professional Regulation (“IDFPR” or “Department”)? While not a welcome event, there are several important things to...more

Venable LLP

The FTC Walks Back Its Rytr Enforcement Action, Signaling a Shift in Federal AI Regulation

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In a rare course correction, the Federal Trade Commission (FTC) has reopened and vacated its 2024 consent order against Rytr LLC, a generative AI-powered company. The unusual move reflects a significant strategic reset of how...more

Parker Poe Adams & Bernstein LLP

FTC Reopens and Vacates Prior Order Against AI Writing Tool Provider

In an unusual move, the Federal Trade Commission (FTC) has reopened and set aside a previously finalized consent order against Rytr LLC, an AI-powered writing tool provider, nullifying the case against the company. ...more

DLA Piper

FTC Issues Consumer Review Warning Letters and Vacates AI Consent Order: Key Points

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On December 22, 2025, the Federal Trade Commission (FTC) announced two actions relating to fake or false consumer reviews: 1. Issuance of a set of warning letters to companies that may be responsible for fake or false...more

Hogan Lovells

In rare move, FTC sets aside Rytr Order for burdening AI innovation (and failing to plead violations)

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The Federal Trade Commission (FTC) has re-opened and set aside its 2024 consent order against generative AI company, Rytr, signaling a shift in how the Commission will approach AI enforcement under President Trump's AI Action...more

Sheppard Mullin Richter & Hampton LLP

Oregon Enters $1.56 Million Consent Order Over Alleged Excessive Interest Charges in Bank Partnership Lending Program

On December 8, the Oregon Department of Consumer and Business Services entered into a consent order with two affiliated companies resolving allegations of violations of the Oregon Consumer Finance Act arising from a bank...more

Mayer Brown

Virtual Currency Exchange Pleads Guilty to Criminal Charges Related to Anti-Money Laundering Violations and Pays Multi-Million...

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On December 9, 2025, the US Department of Justice (“DOJ”) announced a guilty plea by a peer-to-peer convertible virtual currency exchange (the “CVC Exchange”) for conspiring to: (i) violate the Travel Act; (ii) operate an...more

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