At the end of March, FinCEN published a notice of proposed rulemaking (“NPRM”) for its whistleblower program, which has been up and running since 2021. The proposed rules are a welcome development. They are a sign that the Treasury Department appreciates the value of the whistleblowers who have come forward under the program so far […]

Last week, FinCEN announced a historic $80 million penalty against Canaccord, LLC, a broker-dealer, for violations of the Bank Secrecy Act. The penalty is the largest ever imposed against a broker-dealer for BSA violations. This news is a ringing reminder to broker-dealers that despite the Bank Secrecy Act having “Bank” in its name, it applies […]

In a much-awaited decision, the Supreme Court today held in Learning Resources, Inc., et al. v. Trump that tariffs President Trump imposed under the International Emergency Economic Powers Act (IEEPA) are invalid. Customs and Border Protection statistics show that about $130 billion in IEEPA tariffs have been collected since 2025. Beyond its major economic impact, […]

A recent study by Boston University professor Jetson Leder-Luis, entitled Can Whistleblowers Root Out Public Expenditure Fraud? Evidence from Medicare, found that deterrence from $1.9 billion in False Claims Act settlement payments generated almost $19 billion in Medicare cost savings – a 10:1 deterrent effect. Professor Leder-Luis concludes that whistleblower-initiated False Claims Act cases are […]

Teachers should make more money. Even principals should make more money. But they probably shouldn’t do it by secretly holding two jobs with overlapping hours at the same time. The Washington, DC Attorney General’s office recently announced a settlement under its District False Claims Act (the DC equivalent of a state False Claims Act) against […]

Last week, OFAC announced a whopping $215,988,868 penalty against a San Francisco venture capital firm for sanctions violations and for failing to comply with an OFAC subpoena. That number represents the maximum applicable civil monetary penalty. According to the agency’s press release, the firm, GVA Capital Ltd., knowingly continued to manage an investment for Russian […]