Anti-Money Laundering October 23, 2025

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

By Jeffrey M. Hanna and Chelsea Smith Press

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 components of the Bank Secrecy Act (“BSA”). Some key proposed changes include: (1) increasing the reporting thresholds, (2) instituting periodic inflation adjustments, and (3) requiring Treasury to update and rationalize reporting processes and related form. Industry groups, including the American Bankers Association and leading credit unions and community banking associations, have expressed support.

This article summarizes the bill’s core provisions that may impact banks, credit unions, money services businesses, and businesses that engage in large cash transactions.

Anti-Money Laundering, Compliance, Enforcement and Prosecution Policy and Trends October 16, 2025

FinCEN Eyes Easing Compliance Burdens on Financial Institutions

By Jeffrey M. Hanna, Elissa Baur and Patrick A. Wallace

The Financial Crimes Enforcement Network (“FinCEN”) has recently taken two steps in furtherance of the Trump Administration’s deregulatory agenda. In late September, FinCEN posted a notice to the Federal Register soliciting comments on a proposed “Survey of the Costs of Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Compliance” to be completed by non-bank financial institutions (“NBFIs”). On October 9, FinCEN published a series of frequently asked questions (“FAQs”) aimed at clarifying the requirements around filing suspicious activity reports (“SARs”). Both actions point to an effort to ease compliance costs and align compliance efforts with law enforcement priorities.

Government Contracts September 10, 2025

Department of Defense Issues Final Rule on Cybersecurity Standards for Contractors

By Edwin O. Childs, Andrew Konia, Abram J. Pafford, Todd R. Steggerda, Jack White, James Dougherty, Jason M. Vespoli, John Sullivan, Sophie Marsh and McGuireWoods LLP

After years of waiting, the U.S. Department of Defense (DoD) posted to the Federal Register for public inspection on September 9, 2025, a final rule implementing the Cybersecurity Maturity Model Certification 2.0 (CMMC 2.0) standards into the Defense Federal Acquisition Regulation Supplement (DFARS) (the Final Rule), which was formally published a day later on September 10, 2025. The Final Rule’s requirements will become effective in the DFARS as of November 10, 2025, and pertain to all DoD contractors and subcontractors. Defense contractors should ensure their compliance with the standards as soon as possible in order to maintain eligibility to compete for DoD contracts and perform DoD subcontracts, as well as to avoid bid protests and/or civil False Claims Act allegations.

Enforcement and Prosecution Policy and Trends August 15, 2025

State AGs Step Up Enforcement: Recent Lessons from Privacy Law Enforcement in Connecticut and Nebraska

By Nathanael Williams, Erin Ashwell and Eric Olshan

As comprehensive state privacy laws continue to take root across the United States, recent enforcement actions by the attorneys general of Connecticut and Nebraska highlight an important shift — ensuring privacy law compliance vis-à-vis comprehensive privacy laws or other means is a top enforcement priority outside of California.

Read on to learn more about state actions in Connecticut and Nebraska and how they highlight how companies that prioritize consumer trust and regulatory compliance stay ahead of the curve.

Fraud, Deception and False Claims August 4, 2025

California Defense Contractor and Private Equity Firm Agree to Pay $1.75M to Resolve False Claims Act Liability Relating to Voluntary Self-Disclosure of Cybersecurity Violations

By Todd R. Steggerda, Edwin O. Childs, Michael J. Podberesky, Abram J. Pafford, Brett Barnett, Jack White, Andrew Konia, Jason M. Vespoli, John Sullivan and McGuireWoods LLP

On July 31, 2025, the U.S. Department of Justice (“DOJ”) announced a $1.75 million False Claims Act (“FCA”) settlement with Aero Turbine Inc. (“Aero Turbine”), a California-based defense contractor, and private equity firm Gallant Capital Partners LLC (“Gallant Capital”). The settlement arises out of allegations that Aero Turbine failed to comply with certain cybersecurity requirements under an Air Force contract and provided impermissible foreign third party access to sensitive defense information. This settlement highlights yet another example of the DOJ’s increased scrutiny of cybersecurity requirements (under the Cyber Fraud Task Force), specifically including the protection of Controlled Defense Information (“CDI”), under the FCA. The settlement is also an example of DOJ’s focus on (1) pursuing private equity investors and (2) rewarding entities that self-disclose and remediate wrongdoing.

Anti-Money Laundering July 31, 2025

FinCEN Hits Pause: AML Rule for Investment Advisers Delayed

By Jeffrey M. Hanna, Todd M. Beaton, Jr., Jackie Wells and Chelsea Smith Press

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 and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers.

Enforcement and Prosecution Policy and Trends July 11, 2025

DOJ’s Antitrust Division Announces New Whistleblower Rewards Program

By J. Brent Justus, Holden Brooks, Nicholas J. Giles, Casey Erin Lucier, Megan Lewis and Christopher Karamanos

Earlier this week, the Justice Department’s Antitrust Division announced that, for the first time ever, it will offer rewards to individuals who report antitrust crimes and related offenses.

Partnering with the United States Postal Service, the Antitrust Division now invites individuals with original and specific information about antitrust crimes to voluntarily report that information and, in appropriate cases, earn substantial monetary rewards of up to 30% of any criminal fines recovered. While alleged violations must be nominally related to “the Postal Service, its revenues, or property,” whistleblowers need not articulate a material or significant harm to the USPS to be eligible for the program.

Compliance, Fraud, Deception and False Claims July 11, 2025

DOJ and HHS Reestablish False Claims Act Working Group, Delineate Healthcare Enforcement Priorities

By Michael J. Podberesky, Brett Barnett, Timothy Fry, Edwin O. Childs and McGuireWoods LLP

On July 2, 2025, the U.S. Department of Justice (DOJ) and U.S. Department of Health and Human Services (HHS) announced they will reestablish the DOJ-HHS False Claims Act Working Group. Originally formed in December 2020 at the tail end of the first Trump administration, this partnership focuses on advancing enforcement of the False Claims Act (FCA) as a primary tool to combat healthcare fraud. While some may view the announcement as merely formalizing long-existing cooperation between DOJ and HHS, the announcement is significant in that it signals the administration’s commitment to investigating and prosecuting individuals and entities that commit healthcare fraud. This reinvigoration of the FCA Working Group aligns with President Donald Trump’s plans to “aggressively” enforce the FCA.

Read on to learn what healthcare entities need to know about the reestablished working group.

Anti-Bribery and Corruption June 30, 2025

After a Pause, DOJ’s Updated FCPA Guidelines Focus on Cartels and TCOs, But Corporate Exposure Remains

By Eric Olshan, Patrick Rowan, Justin Givens, Roy Dixon III, Garen S. Marshall, Stephen Weiss, Ryan Buchanan, Alex J. Brackett, Michael F. Easley, Jr., Steven McCool, Elissa Baur, Jason H. Cowley, Caroline Schmidt Burton, V. Kathleen Dougherty and Joie Johnston

Executive Summary: On June 9, Deputy Attorney General Todd Blanche issued a memorandum to the Department of Justice’s Criminal Division, outlining the Department’s focus for pending and future FCPA actions. A day later, Matthew Galeotti, the Head of the Criminal Division, offered more insight into how this administration will approach FCPA investigations and enforcement actions. Both pronouncements make clear that DOJ will target companies operating abroad who partner with foreign actors, especially those with any connection to cartels or transnational criminal organizations. The Criminal Division may also focus more on individual misconduct, rather than corporate liability—a welcome change for companies.

Anti-Bribery and Corruption June 18, 2025

Justice Department Issues First Declination Under NSD’s M&A Safe Harbor Policy to Private Equity Firm, Reinforcing Roadmap for Acquiring Firms

By Garen S. Marshall, Justin Givens, Mindy Sauter and Alex J. Brackett

On June 16, the U.S. Department of Justice’s (DOJ) National Security Division (NSD) and the U.S. Attorney’s Office for the Southern District of Texas (USAO-SDTX) announced their decision to decline prosecution of White Deer Management LLC (White Deer), a private equity firm that voluntarily disclosed export control and sanctions violations committed by its newly acquired portfolio company, Unicat Catalyst Technologies LLC (Unicat).[1] This is the first public declination issued under NSD’s M&A Safe Harbor Policy, which applies to voluntary self-disclosures involving potential violations of export control, sanctions, and national security laws.[2]

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