After years of waiting, the U.S. Department of Defense (DoD) posted to the Federal Register for public inspection on September 9, 2025, a final rule implementing the Cybersecurity Maturity Model Certification 2.0 (CMMC 2.0) standards into the Defense Federal Acquisition
Subject to Inquiry
THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS
The Subject to Inquiry blog, published by McGuireWoods LLP, focuses on legal developments and regulatory compliance issues affecting various industries. It covers topics such as anti-money laundering (AML) and Bank Secrecy Act (BSA) compliance, financial institution regulatory changes, cybersecurity standards for defense contractors, privacy law enforcement by state attorneys general, and False Claims Act settlements related to cybersecurity violations. The blog provides updates on legislative proposals, regulatory agency actions, enforcement trends, and best practices for compliance in areas including financial services, government contracting, data privacy, and cybersecurity.
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State AGs Step Up Enforcement: Recent Lessons from Privacy Law Enforcement in Connecticut and Nebraska
As comprehensive state privacy laws continue to take root across the United States, recent enforcement actions by the attorneys general of Connecticut and Nebraska highlight an important shift — ensuring privacy law compliance vis-à-vis comprehensive privacy laws or other means…
California Defense Contractor and Private Equity Firm Agree to Pay $1.75M to Resolve False Claims Act Liability Relating to Voluntary Self-Disclosure of Cybersecurity Violations
On July 31, 2025, the U.S. Department of Justice (“DOJ”) announced a $1.75 million False Claims Act (“FCA”) settlement with Aero Turbine Inc. (“Aero Turbine”), a California-based defense contractor, and private equity firm Gallant Capital Partners LLC (“Gallant Capital”). The…
FinCEN Hits Pause: AML Rule for Investment Advisers Delayed
In a move to balance regulatory efficiency and cost, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) officially announced on July 21, 2025, that it will postpone the effective date, from January 1, 2026, to January 1, 2028, of the Investment…
DOJ’s Antitrust Division Announces New Whistleblower Rewards Program
Earlier this week, the Justice Department’s Antitrust Division announced that, for the first time ever, it will offer rewards to individuals who report antitrust crimes and related offenses.
Partnering with the United States Postal Service, the Antitrust Division now invites…
DOJ and HHS Reestablish False Claims Act Working Group, Delineate Healthcare Enforcement Priorities
On July 2, 2025, the U.S. Department of Justice (DOJ) and U.S. Department of Health and Human Services (HHS) announced they will reestablish the DOJ-HHS False Claims Act Working Group. Originally formed in December 2020 at the tail end of…
Justice Department Issues First Declination Under NSD’s M&A Safe Harbor Policy to Private Equity Firm, Reinforcing Roadmap for Acquiring Firms
On June 16, the U.S. Department of Justice’s (DOJ) National Security Division (NSD) and the U.S. Attorney’s Office for the Southern District of Texas (USAO-SDTX) announced their decision to decline prosecution of White Deer Management LLC (White Deer), a private…
Order Limiting Strict Liability Has Implications on FDCA Enforcement for Companies, Individuals
On May 9, 2025, President Trump signed an Executive Order titled “Fighting Overcriminalization in Federal Regulations.” The Order seeks to reduce the regulatory burden on Americans and prevent individuals from being criminally penalized for unknowingly violating complex regulations. In pursuit…
The Risks of Rushing In: A Closer Look at DOJ Criminal Division’s Updated Corporate Enforcement Policy in the Broader Enforcement Landscape
I. Introduction: More Clarity, But Not a Complete Roadmap
On June 10, Matthew Galeotti, the Head of the U.S. Department of Justice’s (DOJ) Criminal Division, delivered remarks at an event hosted by the American Conference Institute,[1] in which he…
Healthcare Fraud Enforcement in a Second Trump Administration: Trends, Priorities, and Implications
On May 12, 2025, the United States Department of Justice’s (“DOJ”) Criminal Division released a major policy memorandum outlining its enforcement priorities for the upcoming year. Unsurprisingly, the number one priority for the Division was investigating and prosecuting white-collar crimes…