Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Chelsea Smith Press

Photo of Chelsea Smith Press Chelsea advises broker-dealers, investment advisors, banks, and proprietary trading firms on securities regulatory, compliance, and enforcement matters. Her expertise includes regulatory reporting, best execution, anti-money laundering, core compliance, and market access rules.

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Department of War Launches Research Security Audits: Key Compliance Steps for Higher Education Institutions

Compliance, Enforcement and Prosecution Policy and Trends
Background On August 17, 2026, the Department of War issued formal notifications to 30 domestic academic institutions directing them to initiate immediate and comprehensive reviews of their academic, financial, and research collaborations with foreign entities of concern.  The notifications were executed by the Office of the Under Secretary of War for Research and Engineering and… Continue Reading

Federal Circuit Stays Injunctions Against Section 122 ‘Balance-of-Payments’ Tariffs Pending Appeal

Sanctions, Trade Embargo, and Export Controls
On June 11, 2026, the U.S. Court of Appeals for the Federal Circuit granted the federal government’s motions for a stay pending appeal in State of Oregon v. Trump (Nos. 2026-1804, 2026-1805), consolidated appeals from two decisions of the U.S. Court of International Trade (CIT) that had enjoined enforcement of tariffs imposed under Proclamation No.… Continue Reading

As Courts Wrestle With Tariff Refund Cases, Importers Should Confirm Submission of Key Information and Assess Options

Sanctions, Trade Embargo, and Export Controls
Parallel proceedings in two U.S. Court of International Trade cases, Euro-Notions Florida, Inc. v. United States (No. 25-00595) and V.O.S. Selections, Inc. v. United States (No. 25-00066), are rapidly converging on what may be the central unresolved question in the IEEPA tariff refund process: must the government refund duties on entries that have liquidated and… Continue Reading

Reducing BSA Compliance Obligations? A Look at the Senate’s STREAMLINE Act

Anti-Money Laundering
The Senate has introduced the Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act, or the STREAMLINE Act, an initiative led by Senate Banking Committee Chairman Tim Scott and Senator John Kennedy, with support from several Republican co-sponsors. For the first time in over five decades, the bill would modernize key… Continue Reading

FinCEN Hits Pause: AML Rule for Investment Advisers Delayed

Anti-Money Laundering
In a move to balance regulatory efficiency and cost, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) officially announced on July 21, 2025, that it will postpone the effective date, from January 1, 2026, to January 1, 2028, of the Investment Adviser Anti-Money Laundering Rule (“IA AML Rule”), see Anti-Money Laundering/Countering the Financing of Terrorism Program… Continue Reading

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