On January 14, 2026, the French Senate approved a bill[1] extending the scope of legal privilege to consultations of in-house lawyers for the first time (the “Bill”).
Cleary Enforcement Watch
News and Analysis Related to Global Enforcement, White-Collar, and Regulatory Trends and Developments
Cleary Enforcement Watch, published by Cleary Gottlieb Steen & Hamilton LLP, focuses on enforcement developments and regulatory updates primarily in the areas of securities regulation, white-collar defense, and national security law. The blog covers topics such as SEC examination priorities, DOJ enforcement policies including sanctions and export controls, voluntary self-disclosure frameworks in mergers and acquisitions, and evolving criminal enforcement strategies. It also addresses issues related to cybersecurity, emerging technologies like artificial intelligence, compliance programs, and international trade controls. The content is aimed at legal professionals and corporate clients seeking insights into enforcement trends and government investigations.
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Whistleblowing in Focus: Recent Developments, Emerging Issues, and Considerations for Companies (Part Three: Looking Ahead)
Introduction[1]
In this three-part series, we first discuss the outlook for whistleblower programs in the United States under the new administration. Second, we review initiatives relating to whistleblower reports in other jurisdictions over the past year. Third, we address emerging issues…
Whistleblowing in Focus: Recent Developments, Emerging Issues, and Considerations for Companies (Part Two)
Introduction[1]
In this three-part series, we discuss the outlook for whistleblower programs in the United States under the new administration. Second, we review initiatives relating to whistleblower reports in other jurisdictions over the past year. Third, we address emerging issues and…
Whistleblowing in Focus: Recent Developments, Emerging Issues, and Considerations for Companies
Introduction[1]
Many jurisdictions have passed laws promoting and protecting whistleblower reporting, particularly with respect to potential violations of law by companies and their executives, while certain law enforcement authorities have introduced monetary awards programs to provide incentives to report…
SEC Exam Priorities 2026 Priorities Largely Consistent: Will Approach to Deficiencies and Enforcement Referrals Change?
The U.S. Securities and Exchange Commission (“SEC”) Division of Examinations (the “Division”) released its 2026 examination priorities on November 17, 2025 (the “2026 Priorities”). As expected from the new leadership, the 2026 Priorities signal less (but still present) focus on…
Enforcement Countdown: Is DOJ Ready for the Bulk Data Rule “Grace Period” to End?
As of July 8, the U.S. Department of Justice (“DOJ”) is scheduled to begin full enforcement of its Data Security Program (“DSP”) and the recently issued Bulk Data Rule after its 90-day limited enforcement policy expires, ushering in “full compliance”…
DOJ National Security Division Issues First Declination Under Merger-Related Safe Harbor Provisions
On June 16, 2025, the Department of Justice’s National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas announced a landmark declination to prosecute private equity firm White Deer Management LLC following its voluntary self-disclosure…
DOJ Criminal Division Announces White Collar Enforcement Plan and Revisions to Three Key Policies
On May 12, 2025, the Criminal Division of the Department of Justice (“DOJ”) announced several policy changes related to its approach to white collar criminal enforcement. Matthew R. Galeotti, the current head of the Criminal Division, noted that DOJ would be…
DOJ Issues Additional Guidance as Data Security Program Enters into Effect; Limits Enforcement for First 90 Days
On April 11, 2025, the U.S. Department of Justice, National Security Division (“DOJ”) issued a compliance guide (“Compliance Guide”), a set of frequently asked questions (“FAQs”), and a 90-day limited enforcement policy (“Enforcement Policy”) relating to implementation of the Data…
U.S. Government Signals Intent to Increase Enforcement of U.S. Export Controls
Earlier this month, the U.S. Department of Commerce (Commerce), Bureau of Industry and Security (BIS) held its annual Update Conference on Export Controls and Policy (the Conference). During the Conference, key government officials signaled an intent to ramp up enforcement…