- The Order directs federal agencies to strengthen cybersecurity across government systems and critical infrastructure, including through an AI cybersecurity clearinghouse and expanded access to AI-enabled defensive tools for state and local authorities.
- Federal agencies will design a voluntary framework by August 1, 2026, for
President Trump Issues Executive Order on Fintech Innovation, While FRB Proposes Payment Accounts
- The Order requires all federal financial regulators to review existing rules, guidance, and application processes within 90 days and take affirmative steps to encourage fintech innovation within
HSR Update: Fifth Circuit Grants Stay as FTC and DOJ Consider Revisions to HSR Form
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 litigation over the HSR form that took effect in February 2025 and significantly expanded premerger notification requirements. During the stay
DOJ Establishes National Fraud Enforcement Division
- The National Fraud Enforcement Division is dedicated to investigating and prosecuting fraud against “taxpayer dollars and taxpayer-funded programs.”
- The National Fraud Enforcement Division will target real and significant categories of alleged fraud, including healthcare fraud, tax fraud, benefits fraud, and schemes to misappropriate taxpayer dollars.
- The establishment of the National Fraud Enforcement Division further reinforces
New CFTC Enforcement Director Speaks on Priorities, Insider Trading in Prediction Markets, and Cooperation
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
FinCEN Proposes Regulations to Implement Whistleblower Program: 4 Key Takeaways
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 Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) to establish a whistleblower program designed to encourage
Toxic Substances Control Act in Transition: EPA, Courts, and Congress Race to Define TSCA’s Future
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 chemical risk evaluations, the US Environmental Protection Agency (EPA or the Agency) is working to finalize a new iteration of
Executive Order Proposes New Contract Clause Regarding “DEI Discrimination” By Federal Contractors
- A new executive order directs federal agencies to include a contract clause requiring federal contractors and subcontractors to agree not to engage in
FTC Reverts to “Old” HSR Form After Fifth Circuit Denial of FTC Stay Motion
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
DOJ Corporate Enforcement Update: The New Department-Wide Self-Disclosure Policy
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