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18 March 2026

White Collar 2025 Wrap Up & 2026 Forecast

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Benesch Friedlander Coplan & Aronoff LLP

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Attorneys in Benesch's White Collar, Government Investigations & Regulatory Compliance Practice Group weighed in on a wide range of matters, including...
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Attorneys in Benesch's White Collar, Government Investigations & Regulatory Compliance Practice Group weighed inon a wide range of matters, including:

A new class action lawsuit against rap artist Aubrey "Drake" Graham, influencer Adin Ross and the online casino Stake.

The NCAA President's call for stricter state sports betting laws following the NBA betting scandal.

The Streamline Act, meant to allow banks to focus on more meaningful anti-money laundering efforts.

The U.S. Department of Justice and Department of Health and Human Services's joint False Claims Act Working Group to intensify enforcement against fraud involving federal healthcare programs.

Medicaid price reports and the need to accurately include price increases.

The Eleventh Circuit's affirmation of dismissal of a qui tam FCA suit against Quest Diagnostics, finding the FAC did not meet the burden required by Rule 9(b).

The Second Circuit's ruling in United States vs. Chastain, which widens the gap between wire fraud and intangible interests.

Trends

Global white-collar crime enforcement priorities continued to shift in 2025, requiring corporations to adapt swiftly.

In the U.S., the DOJ may focus less on corporate prosecutions and economic fraud while the SEC has subtly changed its injunction approach, especially in insider trading cases.

In Mexico, the government folded the National Transparency, Access to Information, and Personal Data Protection Institute into the new Anti-Corruption and Good Government Secretariat, raising concerns about transparency and the state of its democracy.

The U.K. released guidance on its "failure to prevent fraud" offense, which took effect in September, aiming to ensure organizations are taking action to prevent fraud.

- The FCA revised proposals to publicly name firms under investigation after facing backlash.

China boosted its anti-corruption efforts in healthcare, education and workplace safety.

- A medical corruption crackdown led to 40,000 disciplinary actions and launched a nationwide campaign against corruption in the funeral and burial industry.

SOURCES: Bloomberg, Law360, U.S. Department of Justice, CFTC, The Globe and Mail, U.K. Government, China Daily, Latin Law

Regulatory Developments

Whistleblower programs, whose awards slowed significantly in 2025, are still relevant.

The NWC is calling for reforms to the IRS Whistleblower Program, noting delays in payments, decreased payments and flawed bureaucratic policies.

The SEC Whistleblower Program awarded $255 million to 47 whistleblowers in FY 2024, with 62% being company insiders.

- Awards have slowed significantly in 2025, with reduced funding and a massive backlog contributing to the slowed pace.

The CFTC Whistleblower Program is still awaiting a long-term solution for its funding issue after a stopgap spending bill only extended an emergency short-term fix until March 14.

- The program issued a record 12 award orders in FY 2024.

The DOJ's Corporate Whistleblower Awards Pilot Program, which received 250-plus tips between August and December 2024, appears to be safe.

SOURCES: National Whistleblower Center, American Enterprise Institute for Public Policy Research, SEC, Bloomberg, U.S. Department of Justice

The SEC has subtly changed its injunction approach, using more tailored injunctions—especially in insider trading cases.

A U.S. appeals court has ordered the SEC to reassess the economic impact of its Biden-era rules increasing transparency around short-selling, following a lawsuit by hedge fund groups.

- FINRA has approved a rule change to eliminate the $25,000 minimum equity requirement for pattern day traders, making active day trading more accessible to smaller retail investors. Instead, traders will be subject to an intraday margin rule based on existing maintenance margin requirements.

The SEC and CFTC have announced a new era of collaboration aimed at reducing duplicative regulations and enforcement and held a joint roundtable.

The Spring 2025 Unified Agenda marks a major shift toward deregulation, with agencies streamlining, rescinding or delaying rules and reducing staff. Meanwhile, the CFPB's Spring 2025 Agenda, published in September, outlines 25 regulatory actions at various stages, signaling a move away from expansive rulemaking toward regulatory restraint and review.

SOURCES: Law360, Reuters, SEC, Benesch, CNBC, Forbes, JD Supra

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