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Michael F. Easley, Jr.
Christina Egan
Jeffrey P. Ehrlich
Michael Elliott
Jonathan Ellis

Latest from Subject to Inquiry

The long saga of the Corporate Transparency Act’s (“CTA”) beneficial ownership reporting requirements has reached its final chapter — at least for domestic businesses.  On August 11, 2026, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule permanently exempting all U.S. companies and U.S. persons from reporting beneficial ownership information (“BOI”), which was the…

The explosion of generative AI in the workplace has created a new and largely unaddressed category of litigation risk. In May 2025, a federal court in the Southern District of New York ordered OpenAI to preserve and segregate all ChatGPT output log data that would otherwise be destroyed under its default 30-day deletion policy, marking…

Overview

On July 13, 2026, the Department of War (DoW) announced the immediate suspension of all Cybersecurity Maturity Model Certification (CMMC) Phase II requirements, which had originally been scheduled to take effect November 10, 2026, including the transition to mandatory third-party assessments by CMMC Third-Party Assessment Organizations (C3PAOs) for contractors handling Controlled Unclassified Information (CUI).…

The Office of Foreign Assets Control (“OFAC”) recently issued a proposed rule that will require the implementation and maintenance of a sanctions compliance program (“SCP”) for permitted payment stablecoin issuers (“PPSIs”). 

The proposed rule, which directs that PPSIs put in place a SCP that includes at least five specific elements, deserves immediate attention from the…

Across the healthcare industry, providers are increasingly relying on AI-assisted billing tools to automate medical coding, prior authorization workflows, and the submission of claims to Medicare, Medicaid, and other federal payors. Some vendors advertise “clean” claim rates exceeding 98%, meaning payors almost always accept submitted claims without further intervention or correction. But a high clean-claim…

On June 11, 2026, the U.S. Court of Appeals for the Federal Circuit granted the federal government’s motions for a stay pending appeal in State of Oregon v. Trump (Nos. 2026-1804, 2026-1805), consolidated appeals from two decisions of the U.S. Court of International Trade (CIT) that had enjoined enforcement of tariffs imposed under Proclamation No.…

On June 4, 2026, Representatives Jay Obernolte and Lori Trahan released a discussion draft of the Great American Artificial Intelligence Act (GAAIA). The proposal has generated significant attention, but many organizations may be overestimating its practical significance for their day-to-day operations. The bill is directed primarily at developers of “frontier” AI models, so for most…

Parallel proceedings in two U.S. Court of International Trade cases, Euro-Notions Florida, Inc. v. United States (No. 25-00595) and V.O.S. Selections, Inc. v. United States (No. 25-00066), are rapidly converging on what may be the central unresolved question in the IEEPA tariff refund process: must the government refund duties on entries that have liquidated and…

Key Takeaways

  • The Office of Management and Budget (OMB) proposed sweeping revisions to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards that, among other changes, would prohibit the use of federal funds to support DEI policies that violate federal anti-discrimination laws.
  • The proposed rule introduces a broad discretionary termination provision, modeled

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On May 20, 2026, the U.S. Department of Justice (DOJ) announced a settlement under the False Claims Act (FCA) with two Canada-based steel companies, Farjess Inc. and Royal Canadian Steel Inc., and their part-owner and president, Feroz Jessani, pursuant to which the companies and Jessani agreed to pay $19 million to resolve allegations that they…