Regulatory and Compliance

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On July 9, 2025, the Department of Justice (“DOJ”) commenced enforcement of its new Data Security Program (“DSP”) to prevent foreign adversaries from accessing sensitive U.S. data. Created earlier this year, the program seeks to prevent China (including Hong Kong and Macau), Cuba, Iran, North Korea, Russia, and Venezuela (collectively, the “Countries of Concern”), as well as foreign entities or individuals with significant ties to these nations, from gaining access to U.S. government-related data and certain categories of U.S. sensitive personal data. Importantly, the rules apply “regardless of whether the data is anonymized, pseudonymized, de-identified or encrypted.” According to the DOJ, the threat of foreign adversaries collecting and weaponizing U.S. data had become “increasingly urgent, and ensuring prompt compliance with the DSP’s requirements is critical to addressing the administration’s priorities and stopping the flow of U.S. sensitive personal data and government-related data to countries of concern.” The seriousness of any infraction is reflected in the program’s steep civil and criminal penalties. Violators of the DSP could be subject to fines up to $368,136 per violation, or twice the value of each transaction in violation, whichever is greater. Willful violators could face imprisonment of up to 20 years and a $1 million fine.

Each year, upwards of 100,000 music fans pay up to $599 for the ticket price of weekend-long admission to the Coachella Music and Arts festival outside of Palm Springs, California. In 2025, however, nearly 60% of Coachella’s general admission ticket buyers turned to an increasingly ubiquitous short-term loan service to finance the steep cost of admission: Buy Now, Pay Later (“BNPL”). BNPL financial services typically allow consumers to split purchases into four or fewer interest-free installments, often without a traditional credit check. The organizers of Coachella, for example, partnered with a ticketing provider AXS to provide BNPL options allowing festival attendees to purchase tickets for as little as $49.99 up front with the remaining costs due in installments over the next several months.

Stablecoins have emerged as one of the most transformative innovations in the cryptocurrency space, bridging the gap between the volatility of traditional cryptocurrencies like Bitcoin and the stability demanded by mainstream financial systems. This rise has brought with it a wave of innovation, and nowhere is this more apparent than in the growing number of patent applications for stablecoin technologies.

The Federal Trade Commission (“FTC”) has announced a final rulemaking on a unanimous vote that will expand the reporting requirements for mergers and acquisitions under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (the “HSR Act”). The new reporting requirements will go into effect after the new year in mid-January 2025. No changes will be made to the scope of transactions that are subject to HSR reporting.