News & Analysis as of

Voluntary Disclosure

The Volkov Law Group

BIS Imposes $1.5 Million Penalty on Exyte for Unlicensed In-Country Transfers to SMIC

The Volkov Law Group on

On January 7, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an Order resolving an administrative enforcement action against Exyte Management GmbH, a Germany-based company headquartered...more

McDermott Will & Schulte

IRS roundup: December 12, 2025 – January 12, 2026

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for December 12, 2025 – January 12, 2026....more

American Conference Institute (ACI)

[Event] 3rd Advanced Forum on Global Export Controls - February 24th - 25th, Arlington, VA

If you are a trade and legal compliance decision-maker, where can you go to learn, expand your export controls brain trust, and strengthen your strategy? At ACI’s Advanced Forum on Global Export Controls, you’ll connect...more

Barnea Jaffa Lande & Co.

Israel Securities Authority to Capital Market Entities: Voluntary Disclosure Certificates Do Not Relieve You of Due Diligence...

Barnea Jaffa Lande & Co. on

In October, the Israel Securities Authority (ISA) published a directive to Tel Aviv Stock Exchange (TASE) members and trading exchanges regarding the voluntary disclosure procedure announced by the Israel Tax Authority (ITA)....more

Allen Barron, Inc.

The IRS will Discover Your Offshore Financial and Digital Activities

Allen Barron, Inc. on

As long as there have been taxes levied in the world, there have been those who try to work the system or evade taxes altogether. Unfortunately for many, the world has become a much smaller place for those who wish to...more

Allen Barron, Inc.

IRS is Considering Updates to the Voluntary Disclosure Practice

Allen Barron, Inc. on

A request for public comment reveals the IRS is considering updates to the Voluntary Disclosure practice. The agency states its “commitment to improve its processes, and to further incentivize non-compliant taxpayers to come...more

Ropes & Gray LLP

Recent DOJ Actions on Tariffs Underscore Trade Enforcement Focus

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On December 18, the U.S. Department of Justice (“DOJ”) announced resolution of two significant tariff evasion cases. Each highlights key lessons for enforcement under the Trump Administration, including with respect to...more

Torres Trade Law, PLLC

OFAC Enforcement Spotlight: 2025’s Largest Penalty (So Far), Action Against a Freight Forwarder, and More

Torres Trade Law, PLLC on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has ramped up enforcement of economic sanctions across multiple sectors, from trade logistics to financial services and traditional exporters....more

Miller Nash LLP

CARB Eases 2026 Climate Disclosure Enforcement: SB 261 Enforcement Stayed and SB 253 Schedule Clarified

Miller Nash LLP on

California’s climate-disclosure landscape shifted again in late 2025. Most notably, the California Air Resources Board (CARB) announced it will not enforce the January 1, 2026 reporting deadline under SB 261 (climate-related...more

Foley Hoag LLP - White Collar Law &...

DOJ’s Updated FCPA Guidance: What Deputy Attorney General Blanche’s Policy Remarks Signal For Future Enforcement

Key Takeaways: In recent public remarks, the Deputy Attorney General discussed this administration’s FCPA priorities, building on FCPA guidance issued earlier this year....more

Bass, Berry & Sims PLC

OFAC Enforcement Update: Recent Penalties Highlight Expectations Around Beneficial Ownership, Transparency, and Reporting...

Bass, Berry & Sims PLC on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently announced two separate enforcement actions against IPI Partners, LLC and Gracetown, Inc. for violations of Ukraine-/Russia-related...more

Kilpatrick

6 Key Takeaways | Update on Significant Unclaimed Property Issues

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Kilpatrick’s Jordan Goodman presented an update on significant unclaimed property issues nationwide during a Council On State Taxation (COST) webinar on December 5, 2025....more

Orrick, Herrington & Sutcliffe LLP

CFPB Adopts ‘Humility Pledge’ for Examinations, Says 2026 Examination Cycle is ‘Fundamentally Different’ From Prior Ones

On November 21, the CFPB’s Supervision Division announced changes to its supervision examination process, introducing a new “Humility Pledge” to be read by examiners at the start of each exam. The Bureau stated the pledge...more

Holland & Knight LLP

SDNY Offers Companies Facing Investigation New Incentives for Quick Self-Disclosure

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Jay Clayton, U.S. Attorney for the Southern District of New York (SDNY) discussed corporate cooperation and self-disclosure in a fireside chat at the New York City Bar Association's annual International White Collar Symposium...more

Jones Day

CARB Opens Voluntary SB 261 Docket and Issues Enforcement Advisory Following Ninth Circuit Injunction

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The California Air Resources Board ("CARB") has opened a new public docket for voluntary submissions related to SB 261 climate-related financial risk reports, available here. Entities choosing to submit at this time are asked...more

WilmerHale

DOJ Issues First FCPA Deferred Prosecution Agreement Under New Guidelines

WilmerHale on

On November 12, 2025, the US Department of Justice (DOJ) entered into its first deferred prosecution agreement (DPA) for violations of the Foreign Corrupt Practices Act (FCPA) since the beginning of the Trump Administration....more

Ropes & Gray LLP

CARB Confirms Non‑enforcement of SB 261 Deadline and Details Voluntary Docket Process

Ropes & Gray LLP on

As many were settling back into work after the Thanksgiving holiday, the California Air Resources Board (CARB) published an Enforcement Advisory and opened up its public docket for voluntary submissions of SB 261 climate risk...more

Cadwalader, Wickersham & Taft LLP

Millicom Subsidiary Enters into First FCPA Corporate DPA Since FCPA Pause Lifted: Takeaways on Enforcement Landscape and...

On November 10, 2025, Comunicaciones Celulares S.A. (Comcel or Company), a Guatemalan cellular telecommunications services company, entered into a two-year Deferred Prosecution Agreement (DPA or Agreement) with the Department...more

Procopio, Cory, Hargreaves & Savitch LLP

5 Action Items Required Now Before Selling Your S Corporation in Two Years

Selling a business is one of the most significant events in an entrepreneur’s life. Most of the transaction process will be driven by the market, a buyer’s goals, or industry dynamics outside of the seller’s control. There...more

Blake, Cassels & Graydon LLP

L’Agence du revenu du Canada modifie en profondeur le Programme des divulgations volontaires : faits saillants

Dans un souci de rendre le Programme des divulgations volontaires (le « PDV ») plus attrayant, l’Agence du revenu du Canada (l’« ARC ») y a apporté d’importants changements, lesquels entrent en vigueur le 1er octobre 2025....more

Hinckley Allen

Cyberfraud: A New Era of False Claims Act Liability Risk

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Top Five Takeaways from IAPP’s Webinar - False Claims Act (FCA) cybersecurity enforcement has emerged as a Department of Justice (DOJ) priority under the second Trump Administration. In the first nine months of the Trump...more

Morgan Lewis

In the Know: Private Equity and Cross-Border Investment Challenges

Morgan Lewis on

Cross-border considerations are no longer peripheral issues in private equity transactions. Whether through sanctions, export controls, foreign direct investment regimes, or evolving US policy, these factors are now central...more

Kelley Drye & Warren LLP

[Webinar] Environmental Auditing and Penalty Mitigation: Leveraging EPA’s Audit Policy Under the Trump Administration - October...

Co-hosted by Kelley Drye and Fehr Graham, this webinar will provide practical guidance on leveraging the U.S. EPA’s Audit Policy for penalty mitigation. As the Trump Administration’s EPA shifts toward cooperative compliance...more

Akin Gump Strauss Hauer & Feld LLP

UK OFSI Consults on Amending its Civil Enforcement Processes

OFSI reports that since 2022 and the imposition of sanctions on Russia, it has been pursuing a higher number of complex investigations, with a record number of cases being opened in recent years. This is also reflected in the...more

Blake, Cassels & Graydon LLP

Canada Revenue Agency Overhauls the Voluntary Disclosures Program: Key Highlights

To make its voluntary disclosure program (VDP) more attractive, the Canada Revenue Agency (CRA) has implemented significant changes to the program effective October 1, 2025. At a high level, the new VDP...more

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