Rollback, Regulatory Freezes, and Investigations Review

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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 School of Law outlining the Division of Enforcement’s priorities under CFTC Chairman Michael Selig’s leadership.

Noting that “[t]he era of…

The Federal Trade Commission

The ruling impacts those with HSR filings expected to be submitted on or after March 19, 2026.

By Kyra K. Bromley, Patrick C. English, and Peter M. Todaro

The Fifth Circuit has denied the FTC’s motion for a stay pending appeal in Chamber of Commerce v. FTC (No. 26-40094). As a result, while the appeal proceeds, the “old” HSR form (in place prior to February 10, 2025) is in effect. The FTC confirmed that the district court’s…

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The corporate enforcement of any potential corporate criminal misconduct is now governed by a DOJ-wide policy.

On March 10, 2026, the US Department of Justice (DOJ) announced a new department-wide “Corporate Enforcement and Voluntary Self-Disclosure Policy” (the CEP). The CEP addresses the benefits available to companies that voluntarily disclose, cooperate, and remediate potential criminal misconduct. 

The CEP has important practical implications for any company that discovers potential misconduct and must decide what to do next. The CEP seeks to establish…

Federal Trade Commission

The ruling impacts those with HSR filings expected to be submitted on or after February 20, 2026.

By Kyra K. Bromley, Patrick C. English, and Peter M. Todaro

Updated on February 19, 2026

On February 19, 2026, the Fifth Circuit granted an administrative stay, which keeps the “new” Hart-Scott-Rodino (HSR) premerger notification form in place and temporarily stays the district court’s order vacating the new form. The administrative stay will last until further order from the Fifth Circuit. …

United States Securities and Exchange Commission SEC architecture closeup with modern building sign and logo with red flags by glass windows
  • Since the 2014 adoption of asset-level disclosure requirements, there has not been a single public offering of residential mortgage-backed securities. Market participants have cited these requirements as a key barrier to the return of the public securitization market.
  • New and expanding types of asset-backed securities have prompted
…
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The plan seeks to limit AI regulation at the federal and state level, encourages rapid development of AI infrastructure, and warns against ideological bias in models.

By Michael H. Rubin, Sy Damle, Andrew Gass, Ghaith Mahmood, and Fiona M. Maclean

On July 23, 2025, the Trump administration released a 28‑page AI strategy document titled “Winning the Race: America’s AI Action Plan” (the Action Plan or Plan). The Action Plan was drafted pursuant to Executive Order 14179…

Facade Flags Justice Department Building Washington DC

On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the Guidelines) on “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” by the US Department of Justice (DOJ).

The Guidelines follow President Trump’s February 10, 2025, executive order (the Executive Order), which directed DOJ to “(i) cease initiation of any new FCPA investigations or enforcement actions, unless the Attorney General determines that an individual exception should be made; (ii) review in detail all existing FCPA investigations or enforcement…

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The executive order shifts policy on enforcement of criminal regulatory offenses, steering away from criminal enforcement of strict liability offenses in regulatory matters.

By Jennifer L. Bragg, Nicholas McQuaid, and Terra Reynolds

On May 9, 2025, President Trump issued an executive order titled “Fighting Overcriminalization in Federal Regulations” (the Order), aimed at reducing criminal enforcement of federal regulatory offenses in general and strict liability offenses, in particular. The Order also includes several requirements for agencies to increase transparency…

Facade Flags Justice Department Building Washington DC

The Department of Justice has established a new Civil Rights Fraud Initiative, which will leverage the False Claims Act to investigate and pursue claims against recipients of federal funds who “knowingly violate civil rights laws.”

By Danielle Conley, Terra Reynolds, Anne W. Robinson, Jude Volek, and Savannah Burgoyne

In a memorandum dated May 19, 2025, Deputy Attorney General Todd Blanche announced the establishment of a new Civil Rights Fraud Initiative (the Initiative) at the Department of…