U.S. companies using AI models developed by companies based in the People’s Republic of China, including DeepSeek, Moonshot AI or MiniMax, should be aware of potential congressional scrutiny in this Congress and the next. Two House committees are conducting a joint investigation into the national security, cybersecurity and economic security implications of U.S. companies’ adoption
Subject to Inquiry Blogs
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Talk to Your Customers: Five Agencies Clarify What SAR Confidentiality Actually Prohibits
On September 2, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), the Board of Governors of the Federal Reserve System (“Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), the National Credit Union Administration (“NCUA”), and the Office of the Comptroller of the Currency (“OCC”) issued a joint statement on a question…
Department of War Launches Research Security Audits: Key Compliance Steps for Higher Education Institutions
Background
On August 17, 2026, the Department of War issued formal notifications to 30 domestic academic institutions directing them to initiate immediate and comprehensive reviews of their academic, financial, and research collaborations with foreign entities of concern. The notifications were executed by the Office of the Under Secretary of War for Research and Engineering and…
FinCEN Kills Beneficial Ownership Reporting for U.S. Companies, but Foreign Filers Should Beware
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…
New Frontiers in Spoliation: Preserving AI Records in Litigation
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…
DoW Suspends CMMC Phase II Requirements – Launches 60-Day Review
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).…
OFAC Details Sanctions Compliance Expectations for the Stablecoin Industry
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…
AI-Assisted Billing Could Create FCA Pitfalls: How Healthcare Companies Can Get Ahead of Risk
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…
Federal Circuit Stays Injunctions Against Section 122 ‘Balance-of-Payments’ Tariffs Pending Appeal
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.…
The Great American AI Act: What It Means — and Doesn’t Mean — for Companies Using AI
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…