On December 1, 2025, the U.S. Commodity Futures Trading Commission (CFTC) announced amendments to its Rules Relating to Investigations and Rules of Practice. The amendments are aimed at ...
With new leadership at the SEC, companies have had to grapple less with disclosure mandates and more with macroeconomic and geopolitical headwinds. We address related disclosure implicati...
The CFTC issued an advisory on when it would refer cases to DOJ for criminal investigation and prosecution. The guidance is relatively brief and straightforward, and implements the Presid...
On June 9, 2025, DOJ announced new guidelines for the investigation and enforcement of the Foreign Corrupt Practices Act (FCPA). The Head of DOJ’s Criminal Division also provided additi...
The Department of Justice Criminal Division announced a series of policy changes on white-collar enforcement, covering enforcement priorities, the path to a declination, limitations on mo...
The DOJ has published an enforcement policy and various guidance on its final rule restricting sensitive data transfers to countries of concern, including China.
The SEC has moved with stunning alacrity to put crypto regulation on a sustainable footing. Even as Congress continues to work on a market structure bill, there is still room for addition...
Less than two years after announcing a more aggressive approach to enforcement, the CFTC Division of Enforcement has issued a new policy on self-reporting and cooperation credit that repl...
Davis Polk partner Robert Cohen authored “The Future of Crypto Enforcement in the U.S.” in CoinDesk. In the piece, Robert reviews the formation of the SEC’s crypto enforcement unit ...
Changes to the SEC’s specialized crypto enforcement unit signal a reduced focus on non-fraud crypto cases and increased prioritization of traditional cybersecurity issues, use of emergi...
