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.
On June 30, the Financial Industry Regulatory Authority (FINRA) published an outside expert report setting forth significant recommendations for the management, investigation, review, and resolution of enforcement matters. FINRA commissioned the review in July 2025 as part of its FINRA Forward modernization initiative, retaining Professor Paul Eckert of William & Mary Law School and former SEC Commissioner Troy Paredes to evaluate opportunities for “meaningful, common-sense improvements” to FINRA’s enforcement program.
On June 26, 2026, the European Commission (Commission) published its long-awaited guidelines on the Forced Labor Regulation (FLR). The FLR, which entered into force in December 2024 (see Sidley Update of December 2024) and will apply in full from December 14, 2027, introduces a broad ban on products made, wholly or partly, with forced labor at any stage of the supply chain, regardless of product type, sector, or origin.
http://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.png00Sven De Knophttp://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngSven De Knop2026-07-07 10:23:212026-07-09 13:40:59EU Forced Labor Regulation Moves Toward Implementation: How Companies Should Prepare
The Administration has taken another significant step in its effort to increase pressure on state Medicaid Fraud Control Units (“MFCUs”). On July 2, 2026, the United States Attorney’s Office for the Northern District of New York announced the U.S. Department of Health and Human Services Office of Inspector General (“HHS-OIG”) denied recertification of New York’s MFCU and suspended its federal funding effective July 1. The decision follows the Administration’s announcements earlier this year that it would closely scrutinize state MFCU performance, including through funding consequences for states perceived as failing to aggressively investigate and prosecute Medicaid fraud.
http://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.png00Jaime L.M. Joneshttp://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngJaime L.M. Jones2026-07-06 15:18:462026-07-06 15:18:46HHS-OIG Decertifies New York Medicaid Fraud Control Unit, Escalating Federal Scrutiny of State Medicaid Fraud Enforcement
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.
White Collar Watch
External Review Recommends Sweeping Changes to FINRA Enforcement Program
On June 30, the Financial Industry Regulatory Authority (FINRA) published an outside expert report setting forth significant recommendations for the management, investigation, review, and resolution of enforcement matters. FINRA commissioned the review in July 2025 as part of its FINRA Forward modernization initiative, retaining Professor Paul Eckert of William & Mary Law School and former SEC Commissioner Troy Paredes to evaluate opportunities for “meaningful, common-sense improvements” to FINRA’s enforcement program.
Kenyon Hall
Boston
kenyon.hall@sidley.com
Michael F. Proctor
Washington, D.C.
mproctor@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
Nicole K. Chipi
Miami
nchipi@sidley.com
Rachel Layne
EU Forced Labor Regulation Moves Toward Implementation: How Companies Should Prepare
On June 26, 2026, the European Commission (Commission) published its long-awaited guidelines on the Forced Labor Regulation (FLR). The FLR, which entered into force in December 2024 (see Sidley Update of December 2024) and will apply in full from December 14, 2027, introduces a broad ban on products made, wholly or partly, with forced labor at any stage of the supply chain, regardless of product type, sector, or origin.
Sven De Knop
Brussels
sdeknop@sidley.com
Nicolas J.S. Lockhart
Geneva
nlockhart@sidley.com
Maryanne W. Kamau
Brussels
mkamau@sidley.com
Alessandra Moroni
Brussels
amoroni@sidley.com
Shambhavi Pandey
Geneva
spandey@sidley.com
Laura Verbeken
Brussels
laura.verbeken@sidley.com
HHS-OIG Decertifies New York Medicaid Fraud Control Unit, Escalating Federal Scrutiny of State Medicaid Fraud Enforcement
The Administration has taken another significant step in its effort to increase pressure on state Medicaid Fraud Control Units (“MFCUs”). On July 2, 2026, the United States Attorney’s Office for the Northern District of New York announced the U.S. Department of Health and Human Services Office of Inspector General (“HHS-OIG”) denied recertification of New York’s MFCU and suspended its federal funding effective July 1. The decision follows the Administration’s announcements earlier this year that it would closely scrutinize state MFCU performance, including through funding consequences for states perceived as failing to aggressively investigate and prosecute Medicaid fraud.
Jaime L.M. Jones
Chicago
jaime.jones@sidley.com
Lisa H. Miller
Washington, D.C.
lisa.miller@sidley.com
Kenneth G. Coffin
Dallas
kenneth.coffin@sidley.com
Lauren E. McBride
Chicago
lmcbride@sidley.com
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