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In AML & Financial Services Regulatory

United States: Digital asset/blockchain industry implications of the One Big, Beautiful Bill Act (OBBBA) and other emerging federal legislation

by and 7 Mins Read

On July 4, 2025, the One Big, Beautiful Bill Act was signed into law, making important changes to the Internal Revenue Code. The Act has implications for US and non-US companies and their domestic and international transactions, capital investment, and research and development activities, amongst other areas, which carry significant weight for the cryptocurrency/digital asset industry. From cryptocurrency exchanges, payment processors, asset managers and cryptocurrency funds to mining companies, token issuers, custodians, and centralized or decentralized lending platforms, the Act’s provisions reshape the tax landscape in ways that demand close attention.

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In AML & Financial Services Regulatory

United States: Blowing the Whistle on Collusion – New DOJ Antitrust Division Program

by , , and 4 Mins Read

The Department of Justice’s Antitrust Division, in partnership with the U.S. Postal Service, has launched a Whistleblower Rewards Program to combat antitrust crimes. Following the DOJ Criminal Division’s launch of a whistleblower pilot program last year,1 the Antitrust Division is now offering a reward to whistleblowers. Under the new program, individuals who report credible and timely evidence of antitrust collusion—such as price-fixing or bid-rigging and certain monopolization cases—may receive up to 30% of recovered criminal fines. This marks a significant step in expanding detection tools for antitrust violations, with reports to be submitted through a dedicated DOJ webpage.

In ESG

Annual Compliance Conference summary: Supply chains – Navigating ESG and Trade-related Risks

by , , , and 1 Min Read

At the Annual Compliance conference recently held in London, the session on ‘Supply chains – Navigating ESG and Trade-related Risks’ examined the intensifying ESG and trade-related risks facing global supply chains, shaped by shifting political priorities and evolving regulatory frameworks.

In Anti-Corruption

Annual Compliance Conference summary: Keynote Speaker Session with Baroness Margaret Hodge (Former Chair, Public Accounts Committee; Anti-Corruption Champion)

by , , and 4 Mins Read

At the Annual Compliance conference recently held in London, we were honoured to hear from Baroness Hodge at our Annual Compliance Conference. Baroness Hodge offered a candid and comprehensive overview of the UK’s ongoing challenges and opportunities in tackling economic crime, tax avoidance, and illicit finance.

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In Anti-Corruption

Annual Compliance Conference summary: US and UK Enforcement in the Current Climate – Strategic Shifts and Global Implications

by , , and 4 Mins Read

At the Annual Compliance conference recently held in London, the session on ‘US and UK Enforcement in the Current Climate: Strategic Shifts and Global Implications’ explored the evolving enforcement landscape across the UK, US, and Latin America, with a particular focus on strategic priorities, inter-agency cooperation, and the practical implications of recent policy shifts.

In AML & Financial Services Regulatory

United States: SEC reconsiders foreign private issuer framework

by , , , and 2 Mins Read

The Securities and Exchange Commission (SEC) recently published a concept release seeking public comment on redefining the term “foreign private issuer” (FPI). The current framework provides FPIs with less regulation than domestic issuers, based on the understanding that FPIs face different circumstances, such as compliance with home country laws. However, a recent study revealed significant changes in the FPI population, including an increase in China-based issuers incorporated in lightly regulated tax havens. The SEC is concerned that the current FPI definition may no longer be suitable and is considering potential amendments.

In Anti-Corruption

United States: America first — A recasting of DOJ FCPA enforcement policy in the name of national security

by , , , , , , , and 8 Mins Read

The new DOJ FCPA enforcement policy emphasizes US national security and business interests, moving away from solely prosecuting bribery of foreign officials. The focus will be on bribes involving Transnational Criminal Organizations (TCOs), cartels, and those impacting US competitiveness or national security. Routine, locally accepted business practices are deprioritized. The DOJ will exercise discretion to determine if conduct genuinely impacts US interests, leaving other cases to the SEC or foreign regulators. This creates a more nuanced and unpredictable enforcement environment, with clarity expected only as enforcement patterns emerge.

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In ESG

United States: FTC and DOJ File Joint Statement of Interest in Texas-Led ESG Asset Manager Lawsuit

by , , and 7 Mins Read

On 22 May 2025, the U.S. Federal Trade Commission (FTC) and Department of Justice (DOJ) filed a Joint Statement of Interest in a lawsuit led by the State of Texas against three large investment companies. The lawsuit, led by Texas Attorney General Ken Paxton, has been joined by 10 other states and accuses the asset managers of using their positions in climate-focused investment initiatives to manipulate coal markets, driving up the cost of energy and resulting in higher energy prices for American consumers. This action, as the DOJ publicly notes, is the first formal statement by the Agencies in federal court on the antitrust implications of common shareholdings

In Cybersecurity, Data and Tech

United States: The time is now for U.S. companies to examine their cross-border data transfers

by , and 9 Mins Read

In an era of intensifying geopolitical tensions, companies with operations in the U.S. must navigate an increasingly fragmented and national security-driven regulatory landscape governing cross-border transfers of many different types of data, including personal data and technical information used in R&D and patent filings. The US Department of Justice’s new Data Security Program (DSP) essentially prohibits US persons from making certain volumes of Americans’ personal data available to entities headquartered or residing in China (including Hong Kong and Macau), Russia, Venezuela, Iran, Cuba, or North Korea, or their subsidiaries in other countries, unless an exception applies.

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