News & Analysis as of

Mitigation Enforcement Actions

DLA Piper

CFTC issues new enforcement advisory on self-reporting, cooperation, and remediation

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The Commodity Futures Trading Commission (CFTC, or Commission) has issued an enforcement advisory detailing how its Division of Enforcement (Division) will evaluate self-reporting, cooperation, and remediation from companies...more

Bracewell LLP

The CFTC’s New Advisory on Self-Reporting, Cooperation and Remediation

Bracewell LLP on

In an advisory announced February 25, 2025, the Division of Enforcement of the Commodity Futures Trading Commission (CFTC or Commission) announced a new regime for assessing cooperation credit in determining fines in the...more

Husch Blackwell LLP

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

Husch Blackwell LLP on

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

Baker Botts L.L.P.

CFTC Issues Enforcement Advisory Adopting New Approach for Consideration of Self-Reporting, Cooperation, and Remediation

Baker Botts L.L.P. on

On February 25th, the Commodity Futures Trading Commission (CFTC or Commission) adopted a new approach for how the Division of Enforcement (Division) will assess self-reporting, cooperation, and remediation efforts when...more

Sheppard Mullin Richter & Hampton LLP

ALERT: FCC Sets December 31, 2024 Deadline for Providers to Address Robocall Mitigation Database Deficiencies

On December 10, 2024, the FCC’s Enforcement Bureau (“Bureau”) released an order (“Order”) determining that nearly 2,500 providers across the calling chain had submitted deficient submissions to the Commission’s Robocall...more

Morrison & Foerster LLP

Key Points from the 2023 CFIUS Annual Report

On July 23, 2024, the Committee on Foreign Investment in the United States (CFIUS or the “Committee”) released its Annual Report to Congress covering calendar year 2023. In a year that featured lower deal volume, CFIUS...more

Holland & Hart LLP

CFIUS Proposed Rule Aims to Strengthen Penalty and Enforcement Measures

Holland & Hart LLP on

The US Department of the Treasury (Treasury), which chairs the Committee on Foreign Investment in the United States (CFIUS or the Committee), recently released a Notice of Proposed Rulemaking (NPRM) to augment certain CFIUS...more

Sheppard Mullin Richter & Hampton LLP

FTC, Florida Settle with Chargeback Mitigation Company for $150K

On November 7, the FTC and the State of Florida settled with a chargeback mitigation company and its owners for $150,000. The chargeback company was allegedly using deceptive practices, including referencing disclaimers that...more

Bradley Arant Boult Cummings LLP

Washington Targets Loopholes for Sanctions Evasion: How to Mitigate Risks

Since the February 2022 Russian invasion of Ukraine, the U.S. has adopted a new, more aggressive sanctions strategy, increasingly going after parties who enable sanctioned businesses and individuals to conduct business and...more

Morrison & Foerster LLP

New CFIUS Enforcement Guidelines Signal Expanded Compliance Focus

Morrison & Foerster LLP on

In what likely portends enforcement actions in the near future, the U.S. Department of the Treasury published its first ever CFIUS Enforcement and Penalty Guidelines (the “Guidelines”)....more

White & Case LLP

CFIUS Annual Report and Statistics for 2020 Show Encouraging Trends

White & Case LLP on

The Committee on Foreign Investment in the United States (CFIUS) has released its Annual Report for 2020 (Annual Report) as well as certain case statistics, providing insight into recent CFIUS trends. The data reflect a large...more

White & Case LLP

CFIUS Annual Report for 2019 Shows Key Trends; TikTok Faces CFIUS Review and, Together with WeChat, Other US Restrictions

White & Case LLP on

In late July, the Committee on Foreign Investment in the United States (CFIUS) released its Annual Report for 2019, providing insight into recent CFIUS trends. This included encouraging results on CFIUS outcomes for...more

Furia Rubel Communications, Inc.

Truth in Advertising, Cannabis, and the Importance of a Crisis Plan and Social Media Policy

If you’ve ever wondered whether Big Brother is watching you online, the answer is yes. I’m not just referring to the big data and privacy breaches such as Equifax’s recent $700 million settlement which has been reported in...more

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