Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 14 APRIL 2026

U.S. State Privacy Enforcement: Key Priorities And Practical Guidance From State Regulators

Crowell & Moring LLP
Crowell & Moring LLP
Contributor
Crowell & Moring LLP

Crowell & Moring LLP

Crowell & Moring’s Doha office is a full service legal practice that serves as the firm’s regional...

View firm profile
Explore more from Crowell & Moring LLP

At the International Association of Privacy Professionals’ (IAPP) annual conference March 30-31, 2026, enforcement officials from California, Connecticut, Indiana, and Delaware shared their current...

United StatesConsumer Protection
Jason Johnson
Jason Johnson
Linda Malek
Linda Malek

Introduction

At the International Association of Privacy Professionals’ (IAPP) annual conference March 30-31, 2026, enforcement officials from California, Connecticut, Indiana, and Delaware shared their current and upcoming enforcement priorities under U.S. state consumer privacy laws. This alert summarizes the key themes from the panel and offers practical guidance for companies navigating the evolving enforcement landscape.

State regulators and enforcement authorities are working collaboratively, both publicly and behind the scenes, on enforcement and enforcement priorities, often sharing information on potential targets. The enforcement themes outlined below, although focused on certain jurisdictions, reflect an enforcement posture of coordination across multiple state enforcement agencies. 

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

New York City’s Click-to-Cancel Rule: What Businesses Need To Know

New York City has enacted the nation's first municipal click-to-cancel rule, requiring businesses to provide clear disclosures, simple cancellation processes, and advance renewal notices for subscription services. With approximately 30 states already implementing similar regulations and the federal landscape in flux following the FTC's vacated rule, companies now face an increasingly complex patchwork of compliance obligations. The rule takes effect October 1, 2026, and imposes penalties ranging from $525 t
United StatesConsumer Protection
Skadden, Arps, Slate, Meagher & Flom LLP
Skadden, Arps, Slate, Meagher & Flom LLP
Article

Amway To Pay $225 Million Over Alleged False Earnings Claims And Fabricated Sales

The FTC and Washington state secured a record $225 million settlement from Amway and affiliated groups over allegations they misled recruits about earnings potential while pressuring them to buy products with little retail opportunity. The complaint reveals that over three-quarters of U.S. product volume was sold to IBOs themselves rather than retail customers, with fabricated sales reporting masking the recruitment-driven model. The settlement's injunctive provisions establish new standards for earnings cl
United StatesConsumer Protection
Frankfurt Kurnit Klein & Selz PC
Frankfurt Kurnit Klein & Selz PC
Article

FTC Asks Whether Platform Ad Tools Fuel Impersonation Scams

The Federal Trade Commission is exploring whether digital platforms should bear greater responsibility for preventing impersonation ads that falsely pose as legitimate businesses or government agencies. Through an Advance Notice of Proposed Rulemaking, the agency seeks public input on potential amendments to its existing Impersonation Rule, examining how ad-optimization tools and platform practices...
United StatesConsumer Protection
Greenberg Traurig
Greenberg Traurig
Article

The Coming State-Law Litigation Wave Of 2026-27: “Subscription Trap” Class Actions

State-law class actions targeting automatic renewal and subscription practices are accelerating, creating significant litigation risk for companies that rely on recurring revenue models. Recent settlements demonstrate that even technical compliance failures can lead to seven-figure exposure, with California, Illinois, and Virginia statutes driving the most aggressive litigation.
United StatesConsumer Protection
Benesch, Friedlander, Coplan & Aronoff LLP
Benesch, Friedlander, Coplan & Aronoff LLP
Article

NCAA Enjoined From Enforcing New Fifth-Year Eligibility Rule

A federal court has issued a nationwide injunction blocking the NCAA from enforcing its new five-year eligibility rule against Division I athletes who graduated high school in 2022. The ruling creates immediate compliance challenges for athletic departments as they navigate roster management, revenue-sharing caps, and potential penalties while the NCAA appeals the decision.
United StatesConsumer Protection
Buchanan Ingersoll & Rooney
Buchanan Ingersoll & Rooney
Article

Virginia’s Initial Draft Of Adult-use Marijuana Regulations – What You Should Know And What Questions Remain

Virginia's Cannabis Control Authority has released its initial draft of adult-use marijuana regulations, outlining application fees, license caps, and the approval process for the state's anticipated July 2027 launch of recreational cannabis sales. While the draft provides crucial details on licensing requirements and ownership restrictions, significant questions remain about the application timeline and evaluation criteria that will determine which entities receive coveted permits.
United StatesConsumer Protection
Foley Hoag LLP
Foley Hoag LLP
Article

Wiley Consumer Protection Download (September 15, 2026)

This comprehensive newsletter covers recent federal and state consumer protection enforcement actions, including FTC settlements with payment processors, state attorney general lawsuits against tech companies, and advertising challenge decisions. The update examines regulatory developments such as the FTC's withdrawal of its 2021 health app breach policy statement and the launch of a new rule guidance program, while highlighting emerging enforcement priorities around AI-powered advertising, personalized
United StatesConsumer Protection
Wiley Rein
Wiley Rein
Article

Personalized Pricing Scrutiny Expands As FTC Previews Activity And Cities Join States In Weighing New Restrictions

Regulators and legislators have been keenly focused on personalized pricing for several years, and the degree of interest has increased significantly in recent weeks. For example, Seattle passed a law banning the use of personalized pricing in certain grocery sales, a key New York City official publicly advocated for adoption of a multi-industry proposal, and the Federal Trade Commission (FTC) Chairman previewed that more agency action is on the way.
United StatesConsumer Protection
Wiley Rein
Wiley Rein
Article

SBA Extends Deadline For Comments On Historic Overhaul Of Size Standards

The Small Business Administration has extended the comment period for two proposed rules that could dramatically reshape federal government contracting by significantly expanding the pool of entities eligible for small business set-aside procurements. With some size standard thresholds proposed to increase as much as tenfold, these changes would fundamentally alter the makeup of the small business contractor base.
United StatesGovernment, Public Sector
Crowell & Moring LLP
Crowell & Moring LLP
Article

The Lindsey Graham Sanctions Act: What Businesses Need To Know About The New Tariffs

President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act into law on September 18, 2026, establishing mandatory tariffs of up to 500% on Russian goods and up to 100% on goods from countries that continue to buy Russian energy. The Act targets major importers like China, India, and Turkey, with limited relief mechanisms including natural gas exceptions, presidential waivers, and a 270-day winddown period for entities divesting from Russian operations.
GlobalInternational Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

DOT Final Rule Narrows Airline Delay And Cancellation Reporting Obligation Under FAA Reauthorization Act Of 2024

The U.S. Department of Transportation has issued a final rule fundamentally restructuring how airlines report flight delays and cancellations, creating a new reporting category that removes ten specific events from the traditional "Air Carrier" category. This regulatory change, mandated by the FAA Reauthorization Act of 2024 and effective October 2026, will significantly impact how airline performance is measured and perceived by consumers, while reducing carriers' customer service obligations for certain
United StatesTransport
Crowell & Moring LLP
Crowell & Moring LLP
Article

U.S.-China Trade Truce Extended Two Months: BIS Affiliates Rule Suspension Follows

The U.S.-China trade truce has been extended through January 10, 2027, pushing back the effective date of the Bureau of Industry and Security's Affiliates Rule. While the suspension delays immediate compliance obligations, the rule remains in place and companies should use this additional time to prepare their compliance programs before the suspension potentially expires.
GlobalInternational Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

EU Steel Overcapacity Regulation: New Permanent Measure In Force From 1 July 2026

The European Union has replaced its expiring steel safeguard measures with a permanent Steel Overcapacity Regulation, cutting duty-free steel imports by an average of 47% and raising the out-of-quota tariff from 25% to 50%. The new framework introduces a complex tariff-rate quota system distributed across 26 product categories, with country-specific allocations based on historical import shares and special treatment for FTA partners. A groundbreaking "melt and pour" traceability requirement will gradually s
European UnionInternational Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

CBP Issues Notice Of Rulemaking On Executive Order 14411, “Strengthening Customs Enforcement”

U.S. Customs and Border Protection is considering sweeping regulatory changes that would require importers to provide unprecedented visibility into their supply chains, including foreign export documentation, global business identifiers, and AI-driven tracing technologies. These proposed amendments stem from Executive Order 14411 and could fundamentally reshape compliance obligations for companies importing goods into the United States. CBP is seeking public comment on 64 questions by December 1, 2026, offe
United StatesInternational Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

It’s LIVE: The Cyber Resilience Act Reporting Is Mandatory as of Today - 11 September 2026

Manufacturers of connected products must now comply with the EU Cyber Resilience Act's vulnerability and incident reporting obligations through ENISA's newly launched Single Reporting Platform. This comprehensive guide addresses the critical question every manufacturer faces: can your organization report a cybersecurity incident within 24 hours if one occurs tonight?
European UnionCorporate/Commercial Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

CMS Offers Guidance As Scrutiny Rises Over ABA Therapy In Medicaid

Between 2021 and 2025, Medicaid spending on ABA therapy grew six times faster than the number of children who received services, making it one of the fastest-growing areas of Medicaid expenditure, according to CMS. On August 4, 2026, CMS released a toolkit to help state Medicaid and CHIP agencies strengthen their programs and limit fraud, waste, and abuse tied to increased demand for ABA therapy.
United StatesFood, Drugs, Healthcare, Life Sciences
Crowell & Moring LLP
Crowell & Moring LLP