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
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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
U.S.-China Trade Truce Extended Two Months: BIS Affiliates Rule Suspension Follows
State Department Issues Two New Rules Amending the ITAR
On Friday, September 18, 2026, the U.S. Department of State issued two rules amending the International Traffic in Arms Regulations (ITAR). The first, an interim final rule effective October 19, narrows U.S. Munitions List (USML) Category XX(a) controls on certain
Federal Circuit Resolves Court Split Over IDIQ Awardee Standing
When an agency conducts a multiple-award indefinite delivery, indefinite quantity (IDIQ) competition, successful awardees often wonder whether they can protest the agency’s award to other companies at the U.S. Court of Federal Claims. For over a decade, the answer has
FEATURE COMMENT: The Eleventh Circuit Overturns the Zafirov Decision on FCA Qui Tam Constitutionality
On September 1, 2026, the Eleventh Circuit issued its long-anticipated decision in U.S. ex rel. Zafirov v. Florida Medical Associates LLC, holding that the qui tam provisions of the False Claims Act are constitutional because relators are not officers of