With the consequences of FCPA noncompliance ranging from “huge” to “catastrophic,” compliance should be top-of-mind for U.S. companies doing business with third-party intermediaries and subsidiaries overseas. In a conversation with Mimesis Law’s Lee Pacchia, Foley Partner David Simon discusses how companies should approach investigations to go beyond the “who,” “what,” “where,” and “when” to address the “why,” while 1) meeting U.S. government expectations for the investigation, 2) maintaining control of the investigation, and 3) reining in “scope creep.”
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DOE Proposes Significant Changes to Energy Conservation Standards Rulemaking Process
On July 7, 2026, the Department of Energy (DOE) published a notice of proposed rulemaking (NOPR) proposing substantial revisions to DOE’s “Process Rule,” which governs the process DOE uses to develop energy conservation standards and test procedures for consumer products and commercial/industrial equipment pursuant to the Energy Policy and Conservation Act (EPCA). If finalized, the proposal would significantly alter how DOE develops and evaluates new and amended energy conservation standards, with important implications for manufacturers, importers, and distributors of products subject to DOE’s energy efficiency regulations.
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Foley Automotive Update
Foley is here to help you through all aspects of rethinking your long-term business strategies, investments, partnerships, and technology. Contact the authors, your Foley relationship partner, or our Automotive Team to discuss and learn more.
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What Every Multinational Should Know About … the New CBP Supply Chain Integrity Guidelines
On June 12, 2026, U.S. Customs and Border Protection published a new guide intended to help the importing community understand the three principal authorities used to enforce U.S. forced labor import restrictions: 19 U.S.C. § 1307, the Uyghur Forced Labor Prevention Act, and the Countering America’s Adversaries Through Sanctions Act.