The U.S. Department of the Treasury, through the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC) (collectively Treasury) issued a joint notice of proposed rulemaking on April 8, 2026, to implement the anti-money-laundering (AML) and sanctions compliance provisions of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), establishing a regulatory framework for permitted payment stablecoin issuers (PPSIs), hereinafter collectively “the proposed rule.”[1] The proposed rule does not address the GENIUS Act’s customer identification program (CIP) requirements, which are expected to be the subject of a separate rulemaking.
http://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.png00Paul M. Tyrrellhttp://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngPaul M. Tyrrell2026-04-22 12:22:072026-04-22 17:45:29FinCEN, Office of Foreign Assets Control Propose Anti-Money-Laundering Program and Sanctions Requirements for Stablecoin Issuers
On April 7, 2026, the SEC Division of Enforcement published its annual enforcement results for the 2025 fiscal year (October 2024 through September 2025). The Division reported 456 total enforcement actions, the lowest number in at least 20 years, including 303 “stand-alone” actions; 69 “follow-on” administrative proceedings arising from other civil, criminal, or administrative events; and 84 actions against delinquent filers. The SEC also reported approximately $17.9 billion in monetary relief.
https://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/02/GettyImages-1307247030.jpg400600Stephen L. Cohenhttp://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngStephen L. Cohen2026-04-09 21:50:332026-04-22 18:30:06SEC Enforcement FY2025 Results Signal Shift in Priorities in Direct Critique of Prior Administration
This article analyzes the CFTC’s latest guidance and proposed rulemaking efforts shaping the future of prediction markets, signaling a more assertive regulatory approach. It highlights key considerations for market participants, including contract design, manipulation risk, and engagement with regulators and industry stakeholders, particularly in the context of sports-related event contracts. (more…)
Sidley partner Tobias Loss-Eaton is set to argue his first case before the U.S. Supreme Court, representing a former Twitter employee convicted of spying for Saudi Arabia. The case centers on whether federal prosecutors brought an obstruction charge in the proper venue, raising broader constitutional questions about where criminal cases can be tried. Loss-Eaton, who helped bring the case to the Court through Northwestern’s Supreme Court clinic, now prepares to make his debut at the lectern in a closely watched dispute over the limits of federal venue law.
https://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/SupremeCourtBuilding.jpg606833White Collar Watchhttp://whitecollarwatch.sidley.com/wp-content/uploads/sites/8/2026/03/sidleyLogo-e1643922598198.pngWhite Collar Watch2026-03-27 13:15:532026-04-22 17:56:54Sidley’s Loss-Eaton Making Supreme Court Debut in Saudi Spy Case
On March 10, 2026, the U.S. Department of Justice (DOJ or the Department) announced a new Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP). For the first time, the policy establishes a uniform framework governing corporate enforcement decisions across all DOJ components, including U.S. Attorneys’ Offices nationwide, with the exception of the Antitrust Division, which will maintain its separate and longstanding leniency policy. DOJ’s stated goal for the CEP is to promote greater consistency, predictability, transparency, and fairness in DOJ’s prosecutions of corporate criminal matters.
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…)
FinCEN, Office of Foreign Assets Control Propose Anti-Money-Laundering Program and Sanctions Requirements for Stablecoin Issuers
The U.S. Department of the Treasury, through the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC) (collectively Treasury) issued a joint notice of proposed rulemaking on April 8, 2026, to implement the anti-money-laundering (AML) and sanctions compliance provisions of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), establishing a regulatory framework for permitted payment stablecoin issuers (PPSIs), hereinafter collectively “the proposed rule.”[1] The proposed rule does not address the GENIUS Act’s customer identification program (CIP) requirements, which are expected to be the subject of a separate rulemaking.
(more…)
Paul M. Tyrrell
Boston
ptyrrell@sidley.com
Andrew J. Sioson
Washington, D.C.
asioson@sidley.com
Kristin S. Teager
Washington, D.C.
kteager@sidley.com
Stanley J. Boris
Washington, D.C.
sboris@sidley.com
Jess Cheng
New York
jcheng@sidley.com
Maura Rezendes
Washington, D.C.
maura.rezendes@sidley.com
Jen Fernandez
Washington, D.C.
jen.fernandez@sidley.com
Andrew W. Shoyer
Washington, D.C.
ashoyer@sidley.com
SEC Enforcement FY2025 Results Signal Shift in Priorities in Direct Critique of Prior Administration
On April 7, 2026, the SEC Division of Enforcement published its annual enforcement results for the 2025 fiscal year (October 2024 through September 2025). The Division reported 456 total enforcement actions, the lowest number in at least 20 years, including 303 “stand-alone” actions; 69 “follow-on” administrative proceedings arising from other civil, criminal, or administrative events; and 84 actions against delinquent filers. The SEC also reported approximately $17.9 billion in monetary relief.
(more…)
Stephen L. Cohen
Washington, D.C., Boston, ...
scohen@sidley.com
Lara Mehraban
New York
lmehraban@sidley.com
Ranah Esmaili
Washington, D.C., New York
resmaili@sidley.com
W. Hardy Callcott
San Francisco
wcallcott@sidley.com
Simona K. Suh
New York
simona.suh@sidley.com
David S. Petron
Washington, D.C.
dpetron@sidley.com
Christopher R. Mills
Washington, D.C.
cmills@sidley.com
Ike Adams
Washington, D.C.
iadams@sidley.com
Kenyon Hall
Boston
kenyon.hall@sidley.com
Sidley Discusses CFTC Guidance, Advance Notice of Proposed Rulemaking for Prediction Markets
This article analyzes the CFTC’s latest guidance and proposed rulemaking efforts shaping the future of prediction markets, signaling a more assertive regulatory approach. It highlights key considerations for market participants, including contract design, manipulation risk, and engagement with regulators and industry stakeholders, particularly in the context of sports-related event contracts. (more…)
Ian McGinley
New York
ian.mcginley@sidley.com
Kate Lashley
Miami, New York
klashley@sidley.com
Peter Malyshev
Washington, D.C.
peter.malyshev@sidley.com
Nathan A. Howell
Chicago
nhowell@sidley.com
Daniel J. Hay
Washington, D.C.
dhay@sidley.com
Sidley’s Loss-Eaton Making Supreme Court Debut in Saudi Spy Case
Sidley partner Tobias Loss-Eaton is set to argue his first case before the U.S. Supreme Court, representing a former Twitter employee convicted of spying for Saudi Arabia. The case centers on whether federal prosecutors brought an obstruction charge in the proper venue, raising broader constitutional questions about where criminal cases can be tried. Loss-Eaton, who helped bring the case to the Court through Northwestern’s Supreme Court clinic, now prepares to make his debut at the lectern in a closely watched dispute over the limits of federal venue law.
(more…)
White Collar Watch
U.S. DOJ Implements Uniform Corporate Enforcement and Voluntary Self-Disclosure Framework Across All Components Except Antitrust
On March 10, 2026, the U.S. Department of Justice (DOJ or the Department) announced a new Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP). For the first time, the policy establishes a uniform framework governing corporate enforcement decisions across all DOJ components, including U.S. Attorneys’ Offices nationwide, with the exception of the Antitrust Division, which will maintain its separate and longstanding leniency policy. DOJ’s stated goal for the CEP is to promote greater consistency, predictability, transparency, and fairness in DOJ’s prosecutions of corporate criminal matters.
(more…)
White Collar Watch
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
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
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