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Tariffs Are Here – Be Aware of Criminal and Civil Enforcement Risks

On April 2, 2025, President Donald Trump, citing national security concerns, used authority granted under the International Emergency Economic Powers Act of 1977 (IEEPA) to announce a sweeping new tariff regime, with a 10%...more

Delaware Amends Section 220 – Will Scope of ‘Books and Records’ Production Be Limited?

On March 25, 2025, the Delaware Legislature enacted Senate Bill 21, significantly amending the Delaware General Corporation Law. Among its notable changes is an effort to narrow document production under Section 220, which...more

SEC Now Requires Commission Approval for Subpoenas, but Says It Is Not ‘Walking Away’ From Enforcement

On March 10, 2025, the US Securities and Exchange Commission (SEC) adopted a final rule that will require a majority of the Commissioners to agree before the SEC formally opens an investigation. For the past 15 years, that...more

Federal Law Enforcement Recommends Encrypted and Ephemeral Messaging

In light of recent reports of cyberattacks on telecommunications companies, the FBI and the Cybersecurity and Infrastructure Security Agency (CISA) issued a series of reports and statements recommending secure communications,...more

SEC Announces FY2024 Enforcement Results, Including Record-breaking Financial Remedies

The Securities and Exchange Commission (SEC) recently announced its enforcement results for fiscal year 2024, during which the SEC obtained the highest amount of financial remedies in history—$8.2 billion, representing a 66%...more

DOJ Focuses on AI, Emerging Tech in Newly Issued Guidance Updates for Evaluating Corporate Compliance Programs

On September 23, 2024, the Criminal Division of the US Department of Justice (DOJ) issued an updated Evaluation of Corporate Compliance Programs (ECCP). The updated ECCP emphasizes that companies should address risks...more

SEC Remains Focused on Disclosure of Cybersecurity Incidents

Recent Securities and Exchange Commission (SEC) enforcement action and statements by SEC officials show that the Commission remains focused on disclosures regarding cybersecurity incidents. On May 21, 2024, Erik Gerding,...more

Meredith Defeats Securities Class Action in Eighth Circuit

Cooley litigators secured a victory in the US Court of Appeals for the Eighth Circuit for long-time client Meredith Corporation and four of its senior executives in a securities class action filed by a group of investors over...more

Blog: Department of Justice Updates Guidance on Evaluation of Corporate Compliance Programs

On June 1, the DOJ updated its guidance for evaluating a company’s compliance program when resolving corporate investigations. The updated guidance makes clear that prosecutors should consider a company’s particular...more

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