On April 16, 2025, the Trump Administration issued an Executive Order titled “Ensuring Commercial, Cost-Effective Solutions in Federal Contracts,” which establishes the Administration’s policy of procuring “commercially available products and services, including those that can be modified to fill agencies’ needs, to the maximum extent practicable.” This includes procurements made pursuant to the Federal Acquisition
DOJ Signals Shift in White Collar Enforcement: New Policies Stress Proportionality, Partnership, and Clarity
In a major policy address delivered yesterday at the Security Industry and Financial Markets Association’s (SIFMA) Anti-Money Laundering and Financial Crimes Conference in Washington, D.C., Matthew Galeotti, Head of the U.S. Department of Justice’s (DOJ) Criminal Division, announced a significant shift in how DOJ approaches white collar enforcement. The changes reflect a broader recalibration toward
Banks May Provide Cryptocurrency Transaction and Custody Services, but OCC Has Yet to Provide Clear Compliance Requirements
On May 7, 2025, the Office of the Comptroller of the Currency (“OCC”) issued a follow up to its July 2020 Interpretative Letter 1170, which allowed national banks to provide cryptocurrency custody services to their customers.[1] The May 7 letter (Interpretive Letter 1184)[2] further clarified that banks can buy and sell cryptocurrency at
DOJ Targets Neurofeedback Billing in $15 Million Behavioral Health Fraud Case
On March 6, 2025, federal prosecutors charged a Minnesota couple with orchestrating a $15 million healthcare fraud scheme involving overbilling and submission of false claims for neurofeedback and other behavioral health services performed by a network of behavioral health clinics. This newly unsealed federal indictment underscores the Department of Justice’s increasing focus on fraud involving
Another Fintech Company Acquires a National Bank Charter through Merger
On March 17, 2025, the Office of the Comptroller of the Currency (OCC) announced that it conditionally approved a fintech business model for CenTrust Bank, N.A.’s (“CenTrust”), an Illinois based community bank chartered by the OCC.[1] CenTrust was acquired by SmartBiz Loans, which is a fintech company that provides an online platform to connect
Restoring Common Sense to Federal Procurement – The White House
On April 15, 2025, the Trump Administration issued an Executive Order titled “Restoring Common Sense to Federal Procurement” that seeks to reform the Federal Acquisition Regulation (“FAR”) and agency-specific supplements to contain only those “provisions required by statute or essential to sound procurement.” Along with a supplemental fact sheet, the Executive Order states that
Europe Steps Up as U.S. Pauses FCPA Enforcement: What Companies Need to Know About the New International Anti-Corruption Taskforce
In a significant move signaling Europe’s growing autonomy in global anti-corruption enforcement, prosecutors from the United Kingdom, France, and Switzerland have formed a new cross-border alliance: the International Anti-Corruption Prosecutorial Taskforce. Announced on March 20, 2025 by the U.K.’s Serious Fraud Office (SFO), the taskforce is designed to deepen cooperation among these three countries on
Fifth Circuit Concurrence Adds Voice to FCA Constitutionality Questions
A first appellate circuit judge has questioned the False Claim Act’s constitutionality. In the Fifth Circuit’s decision last month in United States ex rel Montcrief v. Peripheral Vascular Assocs., P.A., No. 24-50176, — F. 4th –, 2025 WL 939890 (5th Cir. Mar. 28, 2025), Judge Stuart Kyle Duncan separately wrote a concurring opinion to express
FinCEN Narrows Focus on Southwest Border
In the last few weeks, the Financial Crimes Enforcement Network (FinCEN) has circulated several instructions focusing on money services businesses operating in the southwest United States, answering the current Administration’s call for increased security measures in that area.
On March 11, FinCEN issued a Geographic Targeting Order (GTO) adding more requirements to certain money services
Treasury Department Formally Exempts U.S. Companies from CTA
The guidance U.S. companies have been waiting for after years of ups and downs is finally here. In line with our last update, on March 21, 2025, FinCEN issued an interim final rule exempting U.S. companies and persons from the requirement to report, modify, or correct beneficial ownership information under the Corporate Transparency Act