Photo of Kip Randall

Kip Randall

A former Army officer, Kip now helps corporate and individual clients navigate government investigations. Kip counsels clients through investigations by the Securities and Exchange Commission (SEC); Environmental Protection Agency (EPA); Internal Revenue Service (IRS); Department of Justice (DOJ), including allegations of antitrust and False Claims Act violations; and state attorneys general. As a member of the eDiscovery Solutions group, Kip works at the intersection of eDiscovery and Government Investigations.

Today, Sarah Razaq Sallis authored The Beat Goes On: Investors, Enforcers and the Potential Consequences of a Longer Reporting Cycle in the Dow Jones Risk Journal. Sarah explains that the Securities and Exchange Commission’s (SEC) proposal to let companies shift from quarterly to semiannual reporting may be an efficiency win, but a real risk

On August 20, 2026, Commodity Futures Trading Commission (CFTC) Chairman Michael S. Selig used the inaugural meeting of the agency’s Innovation Advisory Committee (IAC) to outline the agency’s plans to develop a regulatory framework for crypto asset markets using existing CFTC authority, independent of the Digital Asset Market CLARITY Act. In prepared remarks delivered at CFTC headquarters, Chairman Selig confirmed that he has “directed the CFTC staff to begin exploring rules to codify a CFTC market structure for crypto assets using the agency’s existing authorities.”

On August 18, 2026, the Securities and Exchange Commission (SEC or the Commission) charged the former CEO, CFO, and Senior Director of Finance of a Texas-based auto lending company with securities fraud in connection with the collapse of the subprime auto lender. The SEC’s press release and the complaint filed the same day in the U.S. District Court for the Southern District of New York lay out what the SEC alleges was a years-long scheme to keep a failing lender’s securitization pipeline alive by using collateral that, according to the SEC, was in significant part either nonexistent or already pledged to other parties.

On August 5, 2026, the U.S. Attorney’s Office for the District of Maryland announced that a Taiwan-based, publicly traded manufacturer of light-emitting diodes and its U.S.-based subsidiary agreed to pay the United States $5.15 million to resolve allegations that they violated the False Claims Act (FCA), common law, and the Tariff Act of 1930 by “knowingly failing to pay duties owed on LEDs imported from China.”

Two announcements in the span of nine days reflect a significant expansion of federal healthcare fraud enforcement resources. On August 4, DOJ announced expansion of its Northeast Health Care Fraud Strike Force to Philadelphia, marking the fourth geographic expansion in less than a year. Nine days later, on August 13, Assistant Attorney General Colin M. McDonald issued a priorities memorandum for the National Fraud Enforcement Division (the Fraud Division), a new DOJ division announced by President Trump in January 2026 and formally established in April 2026, that places healthcare fraud second on a list of five enforcement priorities and describes plans to enhance the Strike Force model with additional resources, data analytics, and technology.

On August 18, 2026, the Securities and Exchange Commission (the SEC or the Commission) proposed a new rule, titled “Regulation Crypto Assets,” that would create a tailored securities offering regime for certain investment contracts involving crypto assets (the Proposal). The Proposal is the SEC’s first attempt at formal crypto rulemaking, following the Commission’s March 2026 interpretation clarifying how the federal securities laws apply to certain crypto assets and transactions involving crypto assets.

The U.S. Department of Justice (DOJ) continues to treat Paycheck Protection Program (PPP) loan fraud as an enforcement priority. As we have noted in prior updates covering both criminal and civil enforcement, the pace of new cases has not slowed. Below is an overview of significant PPP-related civil enforcement actions from late 2025 through July 2026. In the coming days, we will post a second blog with an update on criminal enforcement.

On August 4, I spoke with Cormac Connor, Todd Gee, Michael Schrier, and Julia Kopcienski for the latest edition of Husch Blackwell’s Government Enforcement, Compliance & Investigations webinar series. The session examined the federal government’s expanding use of the False Claims Act and other mechanisms to enforce the current administration’s anti-discrimination policy.

The first half of 2026 has confirmed that False Claims Act (FCA) enforcement is not only continuing at historically elevated levels but is expanding in scope, sophistication, and institutional backing. With the Department of Justice (DOJ) reporting more than $6.8 billion in FCA settlements and judgments for fiscal year 2025 (the highest annual total on record) and qui tam filings on pace to set another record in FY 2026, federal fund recipients across various industries face a sustained period of heightened scrutiny. This mid-year update synthesizes the most significant developments and offers practical considerations for navigating the current enforcement landscape.