Key Takeaways: Best Practices For Handling Suspicious Activity Reports

On September 30, 2026, the Securities and Exchange Commission (SEC) issued two rule proposals and five notices aimed at expanding investors’ access to private markets. The package would add ways to qualify as an accredited investor, including passing a new exam administered by the Financial Industry Regulatory Authority (FINRA), broaden performance-based compensation and modernize regulated funds, including interval funds and business development companies (BDCs).

The SEC has approved new NYSE and NYSE American listing rules establishing a $0.25 minimum trading price, effective July 1, 2027. A single closing price below this threshold triggers immediate trading suspension and delisting proceedings with no cure period. Companies trading at low share prices must act now during the transition period to implement reverse stock splits and establish monitoring procedures before this hard floor takes effect.

As AI infrastructure spending surges toward $697 billion in 2026, hyperscalers and compute providers are increasingly turning to debt, structured financing, and GPU-backed collateral to fund expansion. While demand projections remain bullish, a critical timing gap is emerging between capital deployment and cash flow generation, creating significant risks for lenders, sponsors, and operators across the ecosystem.

The U.S. Securities and Exchange Commission has proposed Regulation Crypto Assets, introducing two new exemptions from registration requirements and a safe harbor provision for investment contracts involving crypto assets. How will these tailored frameworks—the Startup Exemption for offerings up to $5M and the Fundraising Exemption for larger capital raises—reshape the regulatory landscape for digital asset issuers while preserving investor protections?

The SEC and CFTC have issued coordinated regulatory relief measures that significantly advance crypto-based trading infrastructure in US markets, bypassing Congressional gridlock on the CLARITY Act. These orders establish new frameworks for tokenized securities venues and passive software providers, potentially reshaping how digital assets are traded and accessed in regulated markets.

The SEC has issued a groundbreaking Innovation Exemption allowing tokenized securities venues to facilitate trading of tokenized NMS stocks using automated market makers and liquidity pools. This temporary five-year exemption from exchange and dealer registration requirements establishes conditions for permissioned blockchain-based trading while granting public companies a 30-day window to object to third-party tokenization of their securities.

Moore & Van Allen's Derivatives & Trading team provides comprehensive analysis of recent CFTC and SEC enforcement actions, proposed regulations on crypto assets...

On March 19, 2026, the federal banking agencies issued a package of proposed changes to the regulatory capital requirements for banking institutions of all sizes, from the largest GSIBs and super-regional banks to community banks (the “Proposed Rules”). This package of proposals is a second full attempt at implementing the 2017 “Basel III Endgame” international framework—following the agencies’ initial package of proposals in July 2023 (the “2023 NPR”)—to better reflect credit, trading and operational risk in the calculation of minimum regulatory capital ratios.

The Health Resources and Services Administration has announced a revised 340B Rebate Model Pilot Program for drugs subject to Medicare's Maximum Fair Price, expanding eligibility to manufacturers with selected drugs for 2026 and 2027. The program introduces new data requirements, dispute resolution mechanisms, and stricter compliance monitoring while addressing stakeholder concerns about administrative burden and program integrity.

On May 29, 2026, the Commodity Futures Trading Commission (CFTC) took a series of coordinated actions to establish a domestic regulatory framework for perpetual contracts on digital commodities.

The USPTO has released its latest economic impact report on IP-intensive industries, announced a new community engagement office in North Carolina, and issued several administrative updates including relief for Japanese applicants affected by a severe earthquake. The Patent Trial and Appeal Board has also designated new precedential and informative decisions addressing obviousness-type double patenting and Markush groupings.

The SEC has proposed a comprehensive overhaul of transfer agent regulations that would formally recognize distributed ledger technology and blockchain-based recordkeeping systems within the existing regulatory framework. This modernization effort imposes enhanced operational, safeguarding, and compliance obligations while establishing technology-neutral standards that could significantly impact tokenization initiatives and digital asset market infrastructure.

Washington Attorney General Nick Brown released the state's first Data Privacy Report, examining how the modern data economy incentivizes personal information collection and retention. The report catalogs resulting harms and recommends that lawmakers strengthen privacy protections, enforcement, and public education while highlighting Washington's continued lack of a comprehensive consumer privacy statute despite inspiring other states' privacy laws.

As discussed in previous client alerts, the rapid growth of artificial intelligence (AI), cloud computing, and digital services has dramatically increased demand for data centers.

The US International Trade Commission has opened a rare public comment period on how it should fulfill its data collection and reporting obligations under Section 338 of the Tariff Act of 1930, a long-dormant authority recently invoked by the Trump Administration to impose restrictions on Canadian imports. This presents a unique opportunity for companies and stakeholders to shape from the ground up how the Commission interprets discriminatory foreign trade practices, evaluates allegations, and reports findi

California's Air Resources Board has released significant modifications to its greenhouse gas emissions reporting regulation, deferring the first reporting deadline to November 10, 2026, and clarifying key requirements for companies doing business in California with over $1 billion in annual revenue. The updates provide additional flexibility for 2026 reporting while enforcement of the Climate-Related Financial Risk Act remains paused pending federal litigation.

The sports and gaming industries are evolving faster than existing legal frameworks can accommodate, creating unprecedented jurisdictional battles, regulatory shifts, and commercial opportunities. From the escalating fight over prediction markets between federal regulators and states to the emergence of responsible gaming as a standalone policy priority, the first half of 2026 has reshaped the legal landscape governing these sectors while raising fundamental questions about innovation, consumer protection

The US Department of Justice has signaled a potential expansion of enforcement under the Foreign Agents Registration Act (FARA) and Section 951, despite earlier indications of limited criminal enforcement. Recent regulatory developments, policy announcements, and high-profile prosecutions of US officials suggest a renewed focus on foreign agent disclosure requirements and potential criminal liability for undisclosed relationships with foreign governments.

As investment in data center infrastructure accelerates globally, disputes are emerging from contractual and investment-related risks that commonly accompany large-scale infrastructure projects. This analysis examines the growing wave of contractual claims among owners, contractors, and subcontractors, as well as investment treaty claims that may arise when governmental actions impact overseas data center developments.

The U.S. Department of Justice has announced three major settlements totaling over $558 million against healthcare providers partnering with Medicare Advantage plans for allegedly submitting false diagnosis codes. These enforcement actions reveal DOJ's intensified scrutiny of risk-sharing payment arrangements between Medicare Advantage plans and healthcare providers, while demonstrating the significant benefits that self-disclosure and cooperation can provide to companies facing potential False Claims Act l