The U.S. Department of Justice and the Department of Homeland Security announced on July 14, 2026, that the Trade Fraud Task Force had surpassed $1 billion in criminal and civil recoveries, penalties, forfeitures, and publicly charged losses less than one year after its launch. The announcement confirms a fundamental shift in the federal government’s approach to customs and trade enforcement, reflecting increased emphasis on rigorous criminal prosecution and civil enforcement under the False Claims Act.
http://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.png00Kristin Graham Koehlerhttp://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngKristin Graham Koehler2026-07-24 09:15:202026-07-24 11:17:16DOJ Expands Trade Fraud Enforcement After $1 Billion Milestone
Antitrust enforcement continues to evolve on both sides of the Atlantic, with regulators sharpening their focus on consumer pricing, merger oversight, and national security review. The July 2026 edition of Sidley’s Antitrust and Competition Bulletin highlights several recent developments that signal where enforcement priorities may be headed.
This issue covers the DOJ and FTC’s call for state Attorneys General to investigate potential anticompetitive practices affecting gasoline prices, the Supreme Court’s decision in Trump v. Slaughter expanding presidential authority over FTC commissioners, the FTC’s $12 million HSR settlement, new guidance from the European Competition Network on merger call-in powers, and the EU’s adoption of updated foreign investment screening rules.
Click here to read the full bulletin for Sidley’s perspective on what these developments mean for businesses navigating antitrust compliance, M&A transactions, and an increasingly active global enforcement landscape.
https://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/07/MN-28679-Antitrust-and-Competition-Bulletin-Imagery-for-.com-blog.jpg332600White Collar Watchhttp://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngWhite Collar Watch2026-07-23 11:58:002026-07-23 11:58:00Sidley’s Antitrust and Competition Bulletin: U.S. and EU Authorities Signal Evolving Enforcement Priorities
On July 16, the Delaware Supreme Court held that defendants facing securities fraud and registration claims in administrative proceedings brought by the Delaware Investor Protection Unit are not entitled to a jury trial under the Delaware Constitution, distinguishing the U.S. Supreme Court’s decision in SEC v. Jarkesy. Applying its recently adopted Blue Beach Bungalows framework, the court concluded that the state statutory claims are not sufficiently analogous to common-law actions historically tried before a jury, despite the availability of monetary penalties.
The decision underscores that jury-trial challenges to state administrative enforcement actions will turn on the text and history of each state’s constitution and statutory scheme, rather than Jarkesy alone. With similar challenges pending in other jurisdictions, including Arizona, the ruling provides important guidance for regulators and litigants assessing the continued viability of administrative enforcement proceedings seeking civil penalties. Click here to read the full blog post.
The Financial Crimes Enforcement Network’s (FinCEN) June 12, 2026 guidance, along with the Federal Deposit Insurance Corporation’s (FDIC) July 9, 2026 Financial Institution Letter, signal a significant shift in how regulators expect financial institutions to use Section 314(b) of the USA PATRIOT Act.
Historically viewed as an anti-money laundering (AML) information-sharing tool, Section 314(b) is now expressly recognized as a mechanism for combating fraud. The updated guidance confirms that financial institutions may rely on the provision’s safe harbor to share information relating to suspected fraud, encourages real-time collaboration among institutions, and highlights the role of Section 314(b) in improving suspicious activity reporting and detecting illicit activity more quickly.
Our latest blog post examines the agencies’ expanded interpretation of Section 314(b), including the broader range of fraud-related information that may be shared, FinCEN’s encouragement of joint suspicious activity report (SAR) filings and proactive information sharing, and the governance, compliance, and supervisory considerations for institutions evaluating or expanding their Section 314(b) programs. The post also explores how the guidance reflects the continued convergence of fraud prevention and AML compliance and what these developments may mean for financial institutions’ information-sharing practices and supervisory expectations. Read the full post here.
In a surprising development, on July 13, 2026, the U.S. Department of Justice dismissed with prejudice its landmark economic espionage prosecution against Pangang Group Company, Ltd. and its subsidiaries—a Chinese state-owned enterprise accused of stealing DuPont trade secrets for the benefit of the Chinese government. The dismissal came just one week after trial began, bringing to an end one of the longest-running and most consequential prosecutions under the Economic Espionage Act.
Although the case itself is over, its legal legacy remains. Over more than a decade of litigation, the prosecution produced significant rulings on service of process, foreign sovereign immunity, and the treatment of foreign state-owned enterprises under the Economic Espionage Act and the Foreign Sovereign Immunities Act. Those decisions, together with amendments to Federal Rule of Criminal Procedure 4 prompted by the litigation, will continue to shape future prosecutions.
On June 9, 2026, DOJ announced a settlement with Broadway Electric Inc. (“Broadway”); its subsidiary, Cornerstone Contracting Inc. (“Cornerstone”); and two of their individual executives, for $21.3 million to resolve False Claims Act allegations. The settlement targeted alleged fraud against the Small Business Administration’s (“SBA”) set-aside contract program for service-disabled veteran-owned small businesses (“SDVOSBs”). The settlement suggests that the government is surging resources to both anti-fraud issues generally, and to alleged SBA fraud in particular.
http://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.png00Kristin Graham Koehlerhttp://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngKristin Graham Koehler2026-07-15 11:26:322026-07-15 11:26:32June DOJ/SBA FCA Settlement Highlights Continued Focus on Contractor Compliance
The SEC has released its Spring 2026 regulatory agenda. With nearly 40 action items in the prerule or proposed-rule stages and many proposals scheduled for October 2026, the agenda signals a robust effort focused on reducing compliance burdens, facilitating capital formation, and providing greater regulatory certainty for digital assets.
http://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.png00Sara M. von Althannhttp://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngSara M. von Althann2026-07-13 16:17:292026-07-13 16:17:29What to Expect in SEC Rulemaking: Takeaways From the SEC’s Spring 2026 Regulatory Agenda
Sidley successfully assisted clients Joshua Davis and Aaron Rudolf in obtaining presidential pardons, providing extraordinary relief in connection with prior convictions under the Clean Air Act.
The firm represented Mr. Davis in securing his pardon following a single Clean Air Act violation. Sidley also represented Mr. Rudolf as co-counsel in obtaining his pardon for the same offense.
The pardons follow broader advocacy by Sidley on the scope and fairness of criminal enforcement under the Clean Air Act. In September 2025, Justin Savage testified before the U.S. House Committee on Oversight and Government Reform regarding the rise in these criminal prosecutions, the need for clear statutory authority and fair enforcement, and Mr. Davis’ and Mr. Rudolf’s cases.
DOJ Expands Trade Fraud Enforcement After $1 Billion Milestone
The U.S. Department of Justice and the Department of Homeland Security announced on July 14, 2026, that the Trade Fraud Task Force had surpassed $1 billion in criminal and civil recoveries, penalties, forfeitures, and publicly charged losses less than one year after its launch. The announcement confirms a fundamental shift in the federal government’s approach to customs and trade enforcement, reflecting increased emphasis on rigorous criminal prosecution and civil enforcement under the False Claims Act.
Kristin Graham Koehler
Washington, D.C.
kkoehler@sidley.com
Ted Murphy
Washington, D.C.
ted.murphy@sidley.com
Aaron M. Applebaum
Washington, D.C.
aapplebaum@sidley.com
Anna Carney
Washington, D.C.
anna.carney@sidley.com
Craig Francis Dukin
Washington, D.C.
cdukin@sidley.com
Sidley’s Antitrust and Competition Bulletin: U.S. and EU Authorities Signal Evolving Enforcement Priorities
Antitrust enforcement continues to evolve on both sides of the Atlantic, with regulators sharpening their focus on consumer pricing, merger oversight, and national security review. The July 2026 edition of Sidley’s Antitrust and Competition Bulletin highlights several recent developments that signal where enforcement priorities may be headed.
This issue covers the DOJ and FTC’s call for state Attorneys General to investigate potential anticompetitive practices affecting gasoline prices, the Supreme Court’s decision in Trump v. Slaughter expanding presidential authority over FTC commissioners, the FTC’s $12 million HSR settlement, new guidance from the European Competition Network on merger call-in powers, and the EU’s adoption of updated foreign investment screening rules.
Click here to read the full bulletin for Sidley’s perspective on what these developments mean for businesses navigating antitrust compliance, M&A transactions, and an increasingly active global enforcement landscape.
White Collar Watch
Delaware Supreme Court Rejects Jarkesy-Based Jury Trial Challenge to State Administrative Enforcement Proceeding
On July 16, the Delaware Supreme Court held that defendants facing securities fraud and registration claims in administrative proceedings brought by the Delaware Investor Protection Unit are not entitled to a jury trial under the Delaware Constitution, distinguishing the U.S. Supreme Court’s decision in SEC v. Jarkesy. Applying its recently adopted Blue Beach Bungalows framework, the court concluded that the state statutory claims are not sufficiently analogous to common-law actions historically tried before a jury, despite the availability of monetary penalties.
The decision underscores that jury-trial challenges to state administrative enforcement actions will turn on the text and history of each state’s constitution and statutory scheme, rather than Jarkesy alone. With similar challenges pending in other jurisdictions, including Arizona, the ruling provides important guidance for regulators and litigants assessing the continued viability of administrative enforcement proceedings seeking civil penalties. Click here to read the full blog post.
Ike Adams
Washington, D.C.
iadams@sidley.com
Kathryn L. Alessi
Boston
kalessi@sidley.com
W. Hardy Callcott
San Francisco
wcallcott@sidley.com
Kevin J. Campion
Washington, D.C.
kcampion@sidley.com
Stephen L. Cohen
Washington, D.C., Boston, ...
scohen@sidley.com
Ranah Esmaili
Washington, D.C., New York
resmaili@sidley.com
Kenyon Hall
Boston
kenyon.hall@sidley.com
Elizabeth A. Marino
Boston
emarino@sidley.com
Ian McGinley
New York
ian.mcginley@sidley.com
Lara Mehraban
New York
lmehraban@sidley.com
Christopher R. Mills
Washington, D.C.
cmills@sidley.com
David S. Petron
Washington, D.C.
dpetron@sidley.com
John I. Sakhleh
Washington, D.C.
jsakhleh@sidley.com
Charles A. Sommers
Washington, D.C.
csommers@sidley.com
Simona K. Suh
New York
simona.suh@sidley.com
Corin R. Swift
New York, Boston
corin.swift@sidley.com
Lara C. Thyagarajan
New York, Boston
lthyagarajan@sidley.com
Paul M. Tyrrell
Boston
ptyrrell@sidley.com
Beyond AML: FinCEN and FDIC Clarify That Section 314(b) Safe Harbor Extends to Fraud Prevention
The Financial Crimes Enforcement Network’s (FinCEN) June 12, 2026 guidance, along with the Federal Deposit Insurance Corporation’s (FDIC) July 9, 2026 Financial Institution Letter, signal a significant shift in how regulators expect financial institutions to use Section 314(b) of the USA PATRIOT Act.
Historically viewed as an anti-money laundering (AML) information-sharing tool, Section 314(b) is now expressly recognized as a mechanism for combating fraud. The updated guidance confirms that financial institutions may rely on the provision’s safe harbor to share information relating to suspected fraud, encourages real-time collaboration among institutions, and highlights the role of Section 314(b) in improving suspicious activity reporting and detecting illicit activity more quickly.
Our latest blog post examines the agencies’ expanded interpretation of Section 314(b), including the broader range of fraud-related information that may be shared, FinCEN’s encouragement of joint suspicious activity report (SAR) filings and proactive information sharing, and the governance, compliance, and supervisory considerations for institutions evaluating or expanding their Section 314(b) programs. The post also explores how the guidance reflects the continued convergence of fraud prevention and AML compliance and what these developments may mean for financial institutions’ information-sharing practices and supervisory expectations. Read the full post here.
Kristin Lee
New York
kristin.lee@sidley.com
David I. Monteiro
Dallas
david.monteiro@sidley.com
Michael D. Mann
New York
mdmann@sidley.com
Alexa Poletto
New York
apoletto@sidley.com
Stanley J. Boris
Washington, D.C.
sboris@sidley.com
Brian C. Earl
New York
bearl@sidley.com
Asher J. Zlotnik
New York
asher.zlotnik@sidley.com
DOJ Ends 15-Year-Old Economic Espionage Case—With Prejudice
In a surprising development, on July 13, 2026, the U.S. Department of Justice dismissed with prejudice its landmark economic espionage prosecution against Pangang Group Company, Ltd. and its subsidiaries—a Chinese state-owned enterprise accused of stealing DuPont trade secrets for the benefit of the Chinese government. The dismissal came just one week after trial began, bringing to an end one of the longest-running and most consequential prosecutions under the Economic Espionage Act.
Although the case itself is over, its legal legacy remains. Over more than a decade of litigation, the prosecution produced significant rulings on service of process, foreign sovereign immunity, and the treatment of foreign state-owned enterprises under the Economic Espionage Act and the Foreign Sovereign Immunities Act. Those decisions, together with amendments to Federal Rule of Criminal Procedure 4 prompted by the litigation, will continue to shape future prosecutions.
Sheila A.G. Armbrust
San Francisco
sarmbrust@sidley.com
Michael D. Mann
New York
mdmann@sidley.com
Brian C. Earl
New York
bearl@sidley.com
Micah D. Stewart
New York
micah.stewart@sidley.com
June DOJ/SBA FCA Settlement Highlights Continued Focus on Contractor Compliance
On June 9, 2026, DOJ announced a settlement with Broadway Electric Inc. (“Broadway”); its subsidiary, Cornerstone Contracting Inc. (“Cornerstone”); and two of their individual executives, for $21.3 million to resolve False Claims Act allegations. The settlement targeted alleged fraud against the Small Business Administration’s (“SBA”) set-aside contract program for service-disabled veteran-owned small businesses (“SDVOSBs”). The settlement suggests that the government is surging resources to both anti-fraud issues generally, and to alleged SBA fraud in particular.
Kristin Graham Koehler
Washington, D.C.
kkoehler@sidley.com
Jaime L.M. Jones
Chicago
jaime.jones@sidley.com
H. Boyd Greene IV
Washington, D.C.
bgreene@sidley.com
Kenneth G. Coffin
Dallas
kenneth.coffin@sidley.com
Dana Diaz
Washington, D.C.
dana.diaz@sidley.com
Anna M. Schmitt
Chicago
anna.schmitt@sidley.com
What to Expect in SEC Rulemaking: Takeaways From the SEC’s Spring 2026 Regulatory Agenda
The SEC has released its Spring 2026 regulatory agenda. With nearly 40 action items in the prerule or proposed-rule stages and many proposals scheduled for October 2026, the agenda signals a robust effort focused on reducing compliance burdens, facilitating capital formation, and providing greater regulatory certainty for digital assets.
Sara M. von Althann
Washington, D.C.
svonalthann@sidley.com
Victoria A. Anglin
Los Angeles
vanglin@sidley.com
Sonia Gupta Barros
Washington, D.C.
sbarros@sidley.com
Andrew P. Blake
Washington, D.C.
ablake@sidley.com
W. Hardy Callcott
San Francisco
wcallcott@sidley.com
Chuck Daly
New York, Boston
cdaly@sidley.com
Nathan J. Greene
New York
ngreene@sidley.com
David M. Katz
New York
dkatz@sidley.com
Erin N. Kauffman
Washington, D.C.
ekauffman@sidley.com
Charles A. Sommers
Washington, D.C.
csommers@sidley.com
Martha O. Tabor
New York
martha.tabor@sidley.com
Sidley Secures Presidential Pardons for Two Clients
Sidley successfully assisted clients Joshua Davis and Aaron Rudolf in obtaining presidential pardons, providing extraordinary relief in connection with prior convictions under the Clean Air Act.
The firm represented Mr. Davis in securing his pardon following a single Clean Air Act violation. Sidley also represented Mr. Rudolf as co-counsel in obtaining his pardon for the same offense.
The pardons follow broader advocacy by Sidley on the scope and fairness of criminal enforcement under the Clean Air Act. In September 2025, Justin Savage testified before the U.S. House Committee on Oversight and Government Reform regarding the rise in these criminal prosecutions, the need for clear statutory authority and fair enforcement, and Mr. Davis’ and Mr. Rudolf’s cases.
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