The U.S. Department of Justice (“DOJ”) Data Security Program (“DSP”) 90-day enforcement grace period ended as of July 8, 2025. While the program became effective April 8, 2025, DOJ implemented a 90-day enforcement grace period until July 8, 2025 for good-faith efforts towards compliance (see our previous blog here). With the expiration of the grace period, the majority of the DSP is now effective and will be enforced.Continue Reading DOJ’s 90-Day Data Security Compliance Grace Period is Over: Are You Compliant?

On Tuesday, July 8, the DOJ Antitrust Division announced a first-of-its-kind Antitrust Whistleblower Rewards Program (the “Program”). But the Program’s fine print suggests it may not be as lucrative for whistleblowers as it appears at first blush.Continue Reading New DOJ Antitrust Postal Whistleblower Rewards Program: A Look Under the Shiny Hood

On Monday June 9, 2025, the Deputy Attorney General Todd Blanche released “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act.” This much anticipated update directly responds to Executive Order 14209, signed by President Trump earlier this year, which temporarily paused Foreign Corrupt Practices Act (FCPA) enforcement. The new Guidelines focus FCPA enforcement going forward on protecting U.S. business interests, furthering the Administration’s efforts to stamp out cartels and transnational criminal organizations, and prioritizing prosecution of individuals rather than corporations. Conduct that can be described as “routine business practices” in foreign countries, under the Guidelines, will not be pursued.Continue Reading DOJ Releases Promised Guidelines for Investigation and Enforcement Under the FCPA

Recently, the Texas House of Representatives introduced HB 5007, along with its companion bill SB 2117. The legislation—“Relating to the establishment of the Texas Committee on Foreign Investment to review certain transactions involving certain foreign entities; creating a civil penalty”—is currently under committee review. If enacted, the Lone Star State would become the first state to establish its own interagency committee to screen foreign investments, modeled in part on the federal Committee on Foreign Investment in the United States (CFIUS).Continue Reading Big State, Big Scrutiny: Texas Steps into the Foreign Investment Review Arena

A serious step up in civil and criminal enforcement of customs laws, including tariff evasion, is imminent. In a May 12 memorandum, the Department of Justice’s new Chief of the Criminal Division, Matthew Galeotti, counted as one of the “most urgent” threats to the country “[t]rade and customs fraud, including tariff evasion.” Earlier in the Administration, in a February 2025 speech, Michael Granston, Deputy Assistant Attorney General for the DOJ’s Commercial Litigation Branch identified, as a key example of new enforcement activity, efforts to enforce payment of customs duties on imported goods and reiterated that enforcement against “illegal foreign trade practices” would be a priority for the Administration. Continue Reading Department of Justice Tariff Enforcement Likely to Surge After Tariff Increases and the Administration’s Increased Focus on Protecting Domestic Business

On May 12, 2025, the U.S. Department of Justice (DOJ) announced a major overhaul of its corporate enforcement policy, aiming to incentivize companies to voluntarily self-disclose misconduct. Titled “Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime,” the revised policy was introduced by DOJ Criminal Division Chief Matthew R. Galeotti and promises a “clear path to declination” for qualifying companies. This marks a strategic shift that could significantly alter how corporate entities approach disclosures, investigations, and compliance moving forward.Continue Reading DOJ’s Updated Enforcement Policy: A Game-Changer for Corporate America?

The U.S. Department of Justice (DOJ)’s new data security rule went into effect April 8, 2025. The rule creates what are effectively export controls and requires companies to take measures to prevent U.S. sensitive personal and government-related data from falling into the hands of foreign adversaries. The rule targets transactions (including data brokerage, vendor agreements, employment agreements, and investment agreements) involving access to bulk sensitive personal data or government-related data when those transactions involve identified covered persons or countries of concern (China, Russia, Iran, North Korea, Cuba, and Venezuela).Continue Reading DOJ Announces 90-Day Grace Period for Companies to Comply with New Data Security Rules on Foreign Adversary Access to U.S. Sensitive Data

On March 5, 2025, SuperValu, Inc. (SuperValu), a grocery store chain that operates in-store pharmacies, was cleared of liability by a Central District of Illinois federal jury—finally quashing whistleblower claims that the company improperly over-billed the government and violated the False Claims Act (FCA). This jury verdict came after a long 14-year battle, which included a Supreme Court reversal of lower court decisions on the FCA’s scienter standard.Continue Reading SuperValu Wins False Claims Act Case with a “No Harm, No Foul” Jury Verdict

Just over one month into the second Trump Administration, the crypto industry has notched yet another victory in its longstanding tug-of-war with regulators — perhaps its most significant to date. On February 21, Coinbase Chief Legal Officer Paul Grewal announced via blog post that the U.S. Securities and Exchange Commission (“SEC”) would be dropping its enforcement action against the company. The lawsuit, which claimed that the company had failed to fulfill registration requirements, has been one of the SEC’s highest-profile crypto cases.Continue Reading SEC Withdraws from Prominent Crypto Enforcement Amid Regulatory Shift

Shortly after her confirmation, and just after her swearing-in by Associate Justice Clarence Thomas, U.S. Attorney General Pamela Bondi issued fourteen memoranda that seek to reform the Department of Justice by rescinding prior guidance, issuing new guidance, and establishing new priorities for the nation’s chief law enforcement and prosecuting agency. We examine below the actions taken by Attorney General Bondi. Continue Reading Attorney General Bondi’s Day One Orders for DOJ