In our client alert of September 30, 2026,1 we provided an executive summary of federal banking regulators’ Proposed Third-Party Risk Management Guidance (the “Proposal”), a related joint statement on community banks’ engagement with core service providers, and a proposed
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Importers of Chassis Made Outside China With Chinese Parts May Recover AD/CVD Deposits as CIT Again Rejects Commerce’s Scope Ruling
The U.S. Court of International Trade (“CIT”) has again rejected the U.S. Department of Commerce’s (“Commerce”) determination that chassis manufactured in Vietnam with Chinese-origin parts are covered by the antidumping (“AD”) and countervailing duty (“CVD”) orders on chassis from China.
GSA Issues Final Rule on Large Language Model Procurements
Background
On September 28, 2026, the General Services Administration (GSA) issued a new clause for incorporation into government contracts of artificial intelligence systems, 552.239-7001, Basic Safeguarding of Data within Large Language Model Artificial Intelligence Systems, as a GSA Regulation
Let’s Talk FCA
Insurance Coverage for False Claims Act Investigations
Hosts Jason Crawford and Agustin Orozco are joined by special guests Steve Raptis and Caitie Young to discuss insurance coverage issues for companies responding to False Claims Act investigations. This episode describes how
Client Alert: DOJ Fraud Division Issues Corporate Enforcement Directive
On October 1, 2026, the U.S. Department of Justice’s (DOJ) National Fraud Enforcement Division issued Directive 26-12: Corporate Enforcement in the Fight Against Fraud. Assistant Attorney General Colin M. McDonald’s October directive follows his August 2026 memorandum setting the
California Signs Nation-Leading AI Chatbot and Social Media Laws: What Businesses Need to Know
What You Need to Know
Key Takeaway #1 California’s new AI chatbot law — “Adam’s Law” (SB 1119) — requires companion chatbot operators to conduct mandatory independent child safety audits and annual risk assessments, implement crisis protocols for queries involving
FTC Updates (September 14–25, 2026)
The FTC has been active across both consumer protection and competition spaces in the past two weeks. In the consumer protection space, the Commission published guidance on auto dealer price transparency, announced proposed settlements with companies and individuals resolving complaints
State AG News: AI Regulation, Data Protection, Food Safety (September 24-30, 2026)
Each week, Crowell & Moring’s State Attorneys General team highlights significant actions that State AGs have taken. See our State Attorneys General page for more insights. Below are the updates from September 24-30, 2026:
Multistate
- A bipartisan coalition of 26
From Process to Principles: Federal Regulators Propose a New Third-Party Risk Management Framework
On September 11, 2026, the OCC, FDIC, Federal Reserve, and NCUA proposed to replace the 2023 Interagency Guidance on Third-Party Relationships with a shorter, principles-based document.1 Two companion releases complete the package: a final interagency statement on the supervision
State AG News: Consumer Protection, Settlements, Federal Regulation (September 18-23, 2026)
Each week, Crowell & Moring’s State Attorneys General team highlights significant actions that State AGs have taken. See our State Attorneys General page for more insights. Below are the updates from September 18-23, 2026:
Multistate
- A bipartisan coalition of 41