Sidley obtained the early termination of corporate probation, along with relief from all remaining unpaid criminal fines, for a leading aftermarket automotive company in United States v. Rudy’s Performance Parts, Inc., Case No. 24-cr-00336 (D.D.C. Mar. 12, 2026).
The result comes amid an important shift in federal criminal enforcement under the Clean Air Act, a cornerstone federal environmental law governing vehicle emissions. The prior prosecution involved alleged tampering with motor vehicle on-board diagnostic (“OBD”) emissions systems — the systems commonly associated with a vehicle’s “check engine” functions — under a charging theory that the U.S. Department of Justice announced in January 2026 should no longer be pursued criminally. Sidley secured the result through an unopposed motion to terminate probation and fines.
https://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/AdobeStock_504965841.jpg400600Justin A. Savagehttp://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngJustin A. Savage2026-03-16 18:03:482026-04-22 18:36:58Sidley Secures Early Termination of Corporate Probation in Clean Air Act Matter for Leading Aftermarket Automotive Company
A recent speech by Acting Deputy Assistant Attorney General Daniel Glad signals that the U.S. Department of Justice (DOJ) Antitrust Division will continue actively pursuing criminal antitrust violations, with a focus on individual accountability and significant prison sentences as a deterrent. Glad also highlighted increased enforcement activity, the expanding role of the Procurement Collusion Strike Force, and the impact of the new antitrust whistleblower rewards program. Read the full article to learn more about what these developments could mean for companies and their compliance programs.
http://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.png00Lisa H. Millerhttp://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngLisa H. Miller2026-03-12 15:53:172026-04-14 13:26:14Antitrust Crime Enforcement May Escalate Under New Chief
Two weeks after a leadership shakeup in the U.S. Department of Justice (DOJ) Antitrust Division, Acting Deputy Assistant Attorney General for Criminal Enforcement Daniel W. Glad stressed in his first public remarks that the Division’s criminal enforcement program will remain highly active and that individuals involved in criminal antitrust offenses should continue to expect lengthy prison sentences. To drive home this message, Glad highlighted the fact that the Antitrust Division opened nearly 100 criminal investigations in FY 2025 and secured prison sentences that reflected more than a 1,200% increase in prison days imposed year-over-year. He cautioned that individuals who commit criminal antitrust offenses should “be aware that what’s on the line isn’t just a fine — it’s their … liberty.” (more…)
On February 25, 2026, the U.S. Office of the Comptroller of the Currency (OCC) issued a Notice of Proposed Rulemaking (NPRM) that would establish a federal framework for issuance and administration of payment stablecoins by permitted payment stablecoin issuers (PPSIs). The NPRM would implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) by, among other things, establishing approval requirements, permissible and prohibited activities, reserve standards, redemption obligations, capital and operational safeguards, and reporting expectations for permitted payment stablecoin issuers. PPSIs also would be integrated into the OCC’s broader prudential framework, including its capital, assessment, and enforcement authorities. (more…)
http://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.png00Michael D. Lewishttp://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngMichael D. Lewis2026-03-06 15:44:312026-04-15 13:40:10U.S. Office of the Comptroller of the Currency Proposes Comprehensive Supervisory Framework for Payment Stablecoins Under GENIUS Act
U.S. sanctions enforcement activity in 2025 underscored the U.S. government’s continued commitment to robust enforcement of the various sanctions programs primarily administered and enforced by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC’s 2025 enforcement actions also signaled the agency’s substantive priorities and, perhaps most important, highlighted its compliance expectations.
Securities and Shareholder Litigation partner Alex J. Kaplan analyzes the Delaware Court of Chancery’s decision in Giuliano v. Grenfell-Gardner, which addresses Caremark oversight claims in the wake of a company’s bankruptcy. The court dismissed red flag claims against the directors but allowed allegations to proceed that the board failed to implement adequate reporting and compliance systems, while sustaining certain red flag claims against two officers based on internal communications. (more…)
http://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.png00Alex J. Kaplanhttp://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngAlex J. Kaplan2026-02-17 14:28:082026-04-14 13:32:20Sidley Discusses a Unique Caremark Twist Amidst Bankruptcy
A recent analysis examines ongoing enforcement risks tied to drug pricing and Medicaid rebate reporting under the Medicaid Drug Rebate Program (MDRP), focusing on a federal court decision addressing how “strength” should be defined for products with the same concentration but different volumes. The court adopted a broader FDA-based definition and dismissed False Claims Act allegations, but the absence of clear statutory or regulatory guidance leaves room for continued scrutiny and potential shifts in agency interpretation. Read the full article for key takeaways on how courts may approach undefined MDRP terms, how FDA regulations can influence rebate reporting obligations, and practical steps manufacturers can take to mitigate False Claims Act risk through consistent, well documented compliance practices.
Within seven months of announcing its groundbreaking monetary whistleblower awards program for individuals who report potential violations, on January 29, 2026, the U.S. Department of Justice (DOJ) Antitrust Division and the U.S. Postal Service announced the first whistleblower award under the Antitrust Whistleblower Rewards Program, paying $1 million to an individual whose information led to criminal enforcement action. (more…)
http://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.png00Kenneth A. Polite Jr.http://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngKenneth A. Polite Jr.2026-02-09 14:16:532026-04-14 13:34:26Million-Dollar U.S. DOJ Antitrust Reward Underlines Broader and Growing Commitment to Incentivize Corporate Whistleblowers
Sidley Secures Early Termination of Corporate Probation in Clean Air Act Matter for Leading Aftermarket Automotive Company
Sidley obtained the early termination of corporate probation, along with relief from all remaining unpaid criminal fines, for a leading aftermarket automotive company in United States v. Rudy’s Performance Parts, Inc., Case No. 24-cr-00336 (D.D.C. Mar. 12, 2026).
The result comes amid an important shift in federal criminal enforcement under the Clean Air Act, a cornerstone federal environmental law governing vehicle emissions. The prior prosecution involved alleged tampering with motor vehicle on-board diagnostic (“OBD”) emissions systems — the systems commonly associated with a vehicle’s “check engine” functions — under a charging theory that the U.S. Department of Justice announced in January 2026 should no longer be pursued criminally. Sidley secured the result through an unopposed motion to terminate probation and fines.
(more…)
Justin A. Savage
Washington, D.C.
jsavage@sidley.com
Lisa H. Miller
Washington, D.C.
lisa.miller@sidley.com
Ike Adams
Washington, D.C.
iadams@sidley.com
Peter Whitfield
Washington, D.C.
pwhitfield@sidley.com
Rose Quam-Wickham
Washington, D.C.
rquamwickham@sidley.com
Antitrust Crime Enforcement May Escalate Under New Chief
A recent speech by Acting Deputy Assistant Attorney General Daniel Glad signals that the U.S. Department of Justice (DOJ) Antitrust Division will continue actively pursuing criminal antitrust violations, with a focus on individual accountability and significant prison sentences as a deterrent. Glad also highlighted increased enforcement activity, the expanding role of the Procurement Collusion Strike Force, and the impact of the new antitrust whistleblower rewards program. Read the full article to learn more about what these developments could mean for companies and their compliance programs.
(more…)
Lisa H. Miller
Washington, D.C.
lisa.miller@sidley.com
Juan A. Arteaga
New York
juan.arteaga@sidley.com
Takayuki Ono
Chicago, Tokyo
tono@sidley.com
New U.S. DOJ Antitrust Leadership Signals More Criminal Prosecutions and Longer Prison Sentences
Two weeks after a leadership shakeup in the U.S. Department of Justice (DOJ) Antitrust Division, Acting Deputy Assistant Attorney General for Criminal Enforcement Daniel W. Glad stressed in his first public remarks that the Division’s criminal enforcement program will remain highly active and that individuals involved in criminal antitrust offenses should continue to expect lengthy prison sentences. To drive home this message, Glad highlighted the fact that the Antitrust Division opened nearly 100 criminal investigations in FY 2025 and secured prison sentences that reflected more than a 1,200% increase in prison days imposed year-over-year. He cautioned that individuals who commit criminal antitrust offenses should “be aware that what’s on the line isn’t just a fine — it’s their … liberty.”
(more…)
Benjamin Nagin
New York
bnagin@sidley.com
Juan A. Arteaga
New York
juan.arteaga@sidley.com
Laura Collins
Washington, D.C.
laura.collins@sidley.com
Lisa H. Miller
Washington, D.C.
lisa.miller@sidley.com
Takayuki Ono
Chicago, Tokyo
tono@sidley.com
Alyssa M. Hasbrouck
New York
ahasbrouck@sidley.com
U.S. Office of the Comptroller of the Currency Proposes Comprehensive Supervisory Framework for Payment Stablecoins Under GENIUS Act
On February 25, 2026, the U.S. Office of the Comptroller of the Currency (OCC) issued a Notice of Proposed Rulemaking (NPRM) that would establish a federal framework for issuance and administration of payment stablecoins by permitted payment stablecoin issuers (PPSIs). The NPRM would implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) by, among other things, establishing approval requirements, permissible and prohibited activities, reserve standards, redemption obligations, capital and operational safeguards, and reporting expectations for permitted payment stablecoin issuers. PPSIs also would be integrated into the OCC’s broader prudential framework, including its capital, assessment, and enforcement authorities.
(more…)
Michael D. Lewis
Washington, D.C.
michael.lewis@sidley.com
David E. Teitelbaum
Washington, D.C.
dteitelbaum@sidley.com
Kristin S. Teager
Washington, D.C.
kteager@sidley.com
Jess Cheng
New York
jcheng@sidley.com
Stanley J. Boris
Washington, D.C.
sboris@sidley.com
Matthew S. Katz
Washington, D.C.
matthew.katz@sidley.com
Nathan Truong
Washington, D.C.
nathan.truong@sidley.com
Five Key Takeaways From 2025 U.S. Sanctions Enforcement
U.S. sanctions enforcement activity in 2025 underscored the U.S. government’s continued commitment to robust enforcement of the various sanctions programs primarily administered and enforced by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC’s 2025 enforcement actions also signaled the agency’s substantive priorities and, perhaps most important, highlighted its compliance expectations.
(more…)
Jen Fernandez
Washington, D.C.
jen.fernandez@sidley.com
Maura Rezendes
Washington, D.C.
maura.rezendes@sidley.com
Andrew W. Shoyer
Washington, D.C.
ashoyer@sidley.com
Ben Vallimarescu
Washington, D.C.
ben.vallimarescu@sidley.com
James Daher
Washington, D.C.
james.daher@sidley.com
Mine Orer
Washington, D.C.
morer@sidley.com
Sidley Discusses a Unique Caremark Twist Amidst Bankruptcy
Securities and Shareholder Litigation partner Alex J. Kaplan analyzes the Delaware Court of Chancery’s decision in Giuliano v. Grenfell-Gardner, which addresses Caremark oversight claims in the wake of a company’s bankruptcy. The court dismissed red flag claims against the directors but allowed allegations to proceed that the board failed to implement adequate reporting and compliance systems, while sustaining certain red flag claims against two officers based on internal communications. (more…)
Alex J. Kaplan
New York
akaplan@sidley.com
Drug Pricing and Medicaid Rebate Reporting: Enforcement Risk Remains
A recent analysis examines ongoing enforcement risks tied to drug pricing and Medicaid rebate reporting under the Medicaid Drug Rebate Program (MDRP), focusing on a federal court decision addressing how “strength” should be defined for products with the same concentration but different volumes. The court adopted a broader FDA-based definition and dismissed False Claims Act allegations, but the absence of clear statutory or regulatory guidance leaves room for continued scrutiny and potential shifts in agency interpretation. Read the full article for key takeaways on how courts may approach undefined MDRP terms, how FDA regulations can influence rebate reporting obligations, and practical steps manufacturers can take to mitigate False Claims Act risk through consistent, well documented compliance practices.
(more…)
Jaime L.M. Jones
Chicago
jaime.jones@sidley.com
Meenakshi Datta
Chicago
mdatta@sidley.com
Emily Schneider
Washington, D.C.
emily.schneider@sidley.com
Million-Dollar U.S. DOJ Antitrust Reward Underlines Broader and Growing Commitment to Incentivize Corporate Whistleblowers
Within seven months of announcing its groundbreaking monetary whistleblower awards program for individuals who report potential violations, on January 29, 2026, the U.S. Department of Justice (DOJ) Antitrust Division and the U.S. Postal Service announced the first whistleblower award under the Antitrust Whistleblower Rewards Program, paying $1 million to an individual whose information led to criminal enforcement action. (more…)
Kenneth A. Polite Jr.
Washington, D.C., New York
kpolite@sidley.com
Benjamin Nagin
New York
bnagin@sidley.com
Lisa H. Miller
Washington, D.C.
lisa.miller@sidley.com
Corey Roush
Washington, D.C.
corey.roush@sidley.com
Laura Collins
Washington, D.C.
laura.collins@sidley.com
Takayuki Ono
Chicago, Tokyo
tono@sidley.com
Anna Boardman
Washington, D.C.
aboardman@sidley.com
Connor Wise
New York
connor.wise@sidley.com
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