Husch Blackwell LLP

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Executive Summary

On September 18, 2026, the Department of Justice (DOJ) announced two substantial revisions to the Justice Manual that will materially affect False Claims Act (FCA) enforcement and defense strategy:

  • Guidance Documents: DOJ will no longer treat sub-regulatory guidance

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On September 16, 2026, Commodity Futures Trading Commission (CFTC) Director of Enforcement David Miller spoke at DACOM NYC 2026, offering a statement on how the CFTC intends to police prediction markets, carbon credit programs, and traditional derivatives markets alike.…