The announcements reflect the administration’s continued focus on FCA enforcement and raise additional compliance considerations for companies doing business with the government.
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The proposal would expand the conditions for maintaining Section 501(c)(3) status and eliminate existing exceptions for certain race-conscious programs.
On September 4, 2026, the Internal Revenue Service (IRS) published proposed regulations that would significantly expand the requirement that private schools holding tax-exempt status under Section 501(c)(3) maintain racially nondiscriminatory policies. The proposed rules, which would come into effect for taxable…
The suspension halts the third-party assessment requirement for defense contractors handling Controlled Unclassified Information (CUI), but cybersecurity obligations and potential FCA exposure remain.
By Anne W. Robinson, Kyle R. Jefcoat, Dean W. Baxtresser, Morgan L. Maddoux, Drew Diachenko, Chris Caulder, Ysa Gomez-Gonzalez, and Pascal Jakowec
In a July 13, 2026, memorandum (CMMC Reform…
The guidance provides a clear foundation for sponsors, underwriters, and investors to structure and execute data center securitizations with greater certainty and efficiency.
By Kevin T. Fingeret, David G. Siegel, Matt Hays, Michele M. Anderson, Rolaine Soril Bancroft, and Ben Meeks
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The Trump administration has issued a light-touch executive order focused on cyber risks stemming from frontier AI.
By Michael H. Rubin, Andrew Gass, Ghaith Mahmood, Sy Damle, and Fiona Maclean
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The Order aims to integrate digital asset providers and innovative technologies into traditional financial services via broader access to the FRB’s payment infrastructure.
By Jenny Cieplak, Zachary Fallon, Arthur S. Long, Parag Patel, Yvette D. Valdez, Stephen P. Wink, Pia Naib, and Deric Behar
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The stay pauses litigation over the 2025 HSR form while the FTC and DOJ consider revisions.
By Kyra K. Bromley, Patrick C. English, and Peter M. Todaro
On May 26, 2026, the Fifth Circuit granted the US government’s unopposed motion to stay proceedings in Chamber of Commerce v. FTC (No. 26-40094) through December 31, 2026. The stay pauses…
The National Fraud Enforcement Division centralizes existing DOJ fraud resources under a single leadership structure, with plans to rapidly expand prosecutorial capacity nationwide.
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Emphasizing an end to “regulation by enforcement,” the agency will focus on market integrity and fraud offenses and partner with registered exchanges and other authorities.
By Douglas K. Yatter, Catherine Young, and John Federico
On March 31, 2026, David I. Miller, the newly appointed Director of Enforcement at the Commodity Futures Trading Commission (CFTC), delivered remarks at NYU…
The program provides new financial incentives for whistleblowers to report information about potential violations of money laundering and sanctions laws.
By Joseph M. Bargnesi, Les P. Carnegie, Andrew P. Galdes, Eric S. Volkman, Douglas K. Yatter, Jewel Drigo, Allayne Thomas, and Nicole Kerrigan
On March 30, 2026, the US Department of the Treasury’s…
As EPA works to finalize a new existing chemicals risk evaluation framework rule, pending Fifth Circuit decisions and legislation introduced to amend TSCA could complicate the Agency’s plans.
By Julia A. Hatcher, Tom Lee, and Hunter J. Kendrick
For the third time since the Toxic Substances Control Act (TSCA) Section 6 was amended in 2016 to mandate existing…
A recent executive order specifies forthcoming contract language prohibiting federal contractors and subcontractors from engaging in “racially discriminatory” DEI activities.
By Dean W. Baxtresser, Danielle Conley, Kyle R. Jefcoat, Danielle J. McCall, Anne W. Robinson, Jude Volek, Morgan L. Maddoux, Genevieve P. Hoffman, and John (Jack) Ring
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