Welcome to the September 2026 edition of The BR Investigations and Enforcement Forum ("B.R.I.E.F."), Blank Rome's monthly newsletter highlighting enforcement priorities and compliance risk issues impacting businesses domestically and abroad. B.R.I.E.F. delivers concise insights into boardroom resilience, regulatory and sanctions developments, internal investigations, enforcement trends, and evolving financial crime risks.
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September 2026 Enforcement Overview
The enforcement landscape since the August 2026 edition reflects an acceleration of institutional changes signaled earlier this year—and a surge in operational activity across multiple agencies. Federal agencies are not only restructuring, they are deploying new tools and ramping up enforcement.
For companies, the practical message continues to sharpen: enforcement agencies are moving beyond restructuring and into operational deployment. Data-driven fraud detection, cross-agency coordination, and parallel civil-criminal enforcement are no longer aspirational—they are active and accelerating. Companies should ensure their compliance programs, internal controls, and investigations-readiness procedures are calibrated to this new operational tempo.
Recent Developments
DOJ Launches National Fraud Detection Center
On August 24, 2026, the U.S. Department of Justice (“DOJ”) announced the launch of the National Fraud Detection Center (“NFDC”), a prosecutor-led, multi-agency team designed to investigate the most harmful actors defrauding federal government programs. Assistant Attorney General Colin McDonald stated that the NFDC “marks a decisive shift in how the federal government detects and investigates complex fraud” by “breaking down institutional silos, embedding analysts from across the IG community, and leveraging shared technology.”
The NFDC brings together federal law enforcement, financial crime agencies, inspectors general, and state partners, with the objective to identify fraud across government programs.
The NFDC addresses a long-standing gap in cross-program fraud visibility—enabling the government to detect fraud actors who exploit multiple taxpayer-funded programs simultaneously. Companies that participate in federal programs, government contractors, healthcare providers, and financial institutions should expect that the NFDC’s cross-referencing capabilities will significantly increase the likelihood that irregularities flagged in one program will trigger scrutiny across others.
DOJ’s Operation No Doze Targets $245 Million in COVID Loan Fraud
On September 14, 2026, the DOJ’s National Fraud Enforcement Division (the “Fraud Division”), together with the Small Business Administration (“SBA”) and SBA Office of Inspector General (“OIG”), announced the results of Operation No Doze, a summer enforcement surge targeting fraud in SBA’s COVID-era small business loan programs. Conducted between June 12 and September 1, 2026, the operation resulted in felony charges against nearly 80 defendants involving approximately $100 million in intended losses. The operation also included approximately 43 guilty pleas involving approximately $44 million in intended losses and approximately 40 sentencings involving nearly $100 million in intended losses. Collectively, the announced enforcement actions spanned more than 160 criminal defendants and approximately $245 million in intended losses.
The operation involved 44 U.S. Attorney’s Offices and 20 federal and state investigative agencies. Attorney General Todd Blanche stated that the defendants “allegedly fabricated businesses, submitted false payroll and revenue claims, stole identities, and concealed foreign ties on their applications.” In tandem with the announcement, the Fraud Division established three new federal-state cooperation agreements with the Missouri Secretary of State, Nebraska Treasurer, and Kansas Treasurer at the Heartland Fraud Partnership Summit in Kansas City.
Notable cases included a $55.9 million Paycheck Protection Program (“PPP”) and Economic Injury Disaster Loan (“EIDL”) fraud indictment in the Western District of Missouri, a multi-defendant Cuban-national PPP fraud conspiracy in the Northern District of Iowa, and a fraud case involving a company with alleged undisclosed Chinese government ties in the Northern District of Indiana. The SBA also announced that it had suspended approximately 870,000 borrowers associated with $39 billion in suspected fraudulent PPP and COVID EIDL activity.
SEC Issues “Innovation Exemption” for Tokenized NMS Stock
On September 17, 2026, the U.S. Securities and Exchange Commission (“SEC”) issued an “Innovation Exemption” designed to facilitate the trading of tokenized National Market System (“NMS”) stock and issued a companion request for comment. The exemption reflects the SEC’s continued effort—following its March 2026 crypto asset interpretive guidance and August 2026 proposed Regulation Crypto Assets—to develop workable regulatory frameworks for digital asset markets.
The Innovation Exemption is a significant step toward integrating blockchain technology into the traditional equity trading infrastructure. Market participants, trading platforms, broker-dealers, transfer agents, and custodians should evaluate how the exemption may affect their existing operations and compliance obligations. The request for comment signals that additional rulemaking is likely.
SEC Continues Fraud Enforcement: Ponzi Schemes and False Filings
The SEC maintained its active fraud enforcement posture throughout September. On September 10, 2026, the SEC charged a founder and his two New Jersey-based companies in connection with an alleged $16 million Ponzi scheme. On September 1, the SEC charged San Francisco Bay Area private fund executives with a multimillion-dollar Ponzi-like scheme.
On August 27, 2026—shortly after the last edition—the SEC announced that 38 entities had feigned legitimacy as U.S.-registered investment advisers through false filings in order to lure retail investors. The coordinated enforcement action underscores the SEC’s focus on protecting retail investors from fraudulent advisers and fund operators, as well as the agency’s willingness to bring mass enforcement actions targeting registration fraud.
The SEC announced two notable developments in late August and early September 2026. On August 31, 2026, it entered into a Memorandum of Understanding with the FDA to enhance cooperation and safeguard market integrity in industries involving FDA-regulated products. On September 3, 2026, the SEC proposed rescinding the investment adviser political contribution, or “pay-to-play,” rule.
Investment advisers, private fund managers, and broker-dealers should continue to expect SEC scrutiny of registration compliance, fee disclosures, custody practices, and retail-facing sales activity.
OFAC Launches “Operation Economic Outcast” — Unprecedented Iran Sanctions Campaign
Since late August, the Office of Foreign Assets Control (“OFAC”) has executed the most aggressive Iran-related sanctions campaign in recent memory under the banner of “Operation Economic Outcast.” The operation has included multiple waves of designations and enforcement actions.
From August 24 through September 17, 2026, the U.S. Department of the Treasury (“Treasury”) and OFAC imposed several rounds of sanctions targeting Iran’s access to foreign banks, airlines, proxy networks, and digital asset platforms. They also sanctioned criminal and terrorist organizations, eased certain sanctions on Syria, and targeted Cuba’s mineral and military sectors.
Separately, on August 26, Treasury took action against violent far-left terrorist networks, and on August 7, Treasury sanctioned crypto exchanges funding Iran’s Islamic Revolutionary Guard Corps and enabling illicit finance.
BIS Reaches Settlement with Container Manufacturing Ltd.
On August 24, 2026, the Bureau of Industry and Security (“BIS”) announced an administrative enforcement settlement with Container Manufacturing Ltd. This settlement follows the Plexon, Inc. settlement discussed in last month’s edition and the $36 million Bosch penalty announced in June 2026 for violations pertaining to shipments to Huawei.
Export enforcement continues to be a high-priority area for BIS, with settlements and penalties demonstrating the agency’s willingness to pursue violations across a wide range of industries and technologies. Companies with international supply chains should ensure that their export classification, Entity List screening, end-use and end-user due diligence, and deemed export controls are current and tested.
CFTC Resolves Actions Involving False Statements and Event Contract Insider Trading
On September 1, 2026, the Commodity Futures Trading Commission (“CFTC”) resolved an action against a swaps trader for making false statements. On August 28, the CFTC ordered Gabriel Perez to pay $172,000 for insider trading of Mention Market event contracts—a notable action reflecting the CFTC’s continued focus on prediction and event markets as these products grow in popularity and regulatory significance.
The event contract insider trading case is particularly noteworthy given the CFTC’s broader focus on prediction markets throughout 2026. Market participants and platforms should closely monitor the evolving regulatory and enforcement posture toward event contracts and ensure that their trading surveillance and compliance frameworks address insider trading risk in these emerging products.
SEC Charges Former Bank of America Investment Banker with Insider Trading
On August 21, 2026, the SEC charged Jason Satsky, a former senior Bank of America investment banker, with insider trading. According to the SEC’s complaint, Satsky tipped confidential information about a pending merger involving South Jersey Industries to his close friend, Gavin Wolfe, in 2021. Together, they allegedly traded through three front companies—Evergreen Financial, Evergreen Capital, and Empire Property—generating illicit profits. Satsky’s employment was terminated by Bank of America in March 2025. The case follows the SEC’s earlier May 2026 action charging 21 individuals in a decade-long insider trading scheme involving information misappropriated from multiple global law firms. Together, these cases underscore the SEC’s continued focus on insider trading enforcement, including tipper-tippee chains, and the Market Abuse Unit’s willingness to pursue cases involving sophisticated concealment through shell entities.
Companies should ensure that Material Non-Public Information controls, trading surveillance, and wall-crossing procedures remain robust.
Former Bank CEO Sentenced to Over Nine Years for Wire Fraud and Venezuela Sanctions Evasion
On September 21, 2026, Tomás Niembro Concha, a Spanish and Venezuelan national and former CEO of Nodus International Bank, a Puerto Rican international bank, was sentenced to 112 months in prison for conspiracy to commit wire fraud and conspiracy to violate the International Emergency Economic Powers Act (“IEEPA”). Niembro led a scheme to defraud Nodus Bank of at least $24.9 million and conspired to evade U.S. sanctions against Venezuela by devising a scheme to transfer approximately $2.5 million held by a Specially Designated National to Niembro through a sham foreclosure transaction. The sentencing reflects DOJ’s continued willingness to pursue gatekeepers—including bank executives—who abuse their positions to facilitate fraud and sanctions evasion.
Companies and financial institutions should ensure that board-level governance, related-party transaction controls, and OFAC compliance procedures are designed to prevent insiders from exploiting their access.
DOJ Continues FCPA and International Corruption Enforcement
On September 21, 2026, Javier Aguilar, a Mexican national and former oil trader, was sentenced in Brooklyn, New York, to four years in prison for his role in a scheme to bribe Ecuadorian and Mexican government officials. On September 18, DOJ returned approximately $2.5 million in corruption proceeds to the Republic of The Gambia to compensate victims of the Jammeh regime. On September 17, DOJ returned approximately $29.7 million in proceeds of fraud, money laundering, and tax evasion to the Government of Curaçao.
These actions demonstrate the Criminal Division's continued focus on foreign bribery, international asset recovery, kleptocracy, and cross-border corruption enforcement. While the sentencing of former oil trader Javier Aguilar underscores DOJ's continued commitment to FCPA enforcement, the asset returns to The Gambia and Curaçao reflect a parallel emphasis on recovering and repatriating illicit proceeds obtained through corruption, fraud, money laundering, and related financial crimes.
DOJ Charges Two in $230 Million Cryptocurrency Scam
In September 2026, a federal grand jury in the District of Columbia returned an indictment charging two individuals in connection with a $230 million cryptocurrency scam. The case adds to the growing body of crypto-related criminal enforcement activity across DOJ, the SEC, and the CFTC, and reflects DOJ’s willingness to pursue large-scale digital asset fraud through the criminal justice system.
Companies, exchanges, custodians, and intermediaries in the digital asset ecosystem should expect parallel enforcement across agencies and should ensure that their anti-money laundering/know your customer, transaction monitoring, and fraud detection systems are calibrated for the unique risks of crypto asset markets.
Blank Rome News & Notes
Blank Rome Earns #1 National Ranking in The American Lawyer’s 2026 Midlevel Associates Survey. On September 1, 2026, Blank Rome earned the No.1 national ranking in The American Lawyer’s 2026 Midlevel Associates Survey, including No.1 in Philadelphia and No.1 in Washington, D.C. The ranking reflects the firm’s continued investment in its people, culture, and professional development. Read more >>
ABA International White Collar Crime Institute Panel on Supply Chain Investigations. Partner, Brad Henry will serve as a panelist at the ABA International White Collar Crime Institute, joining Claire Cross, Astrid Mignon Colombet, and Jamas Hodivala KC for a session exploring emerging investigations, enforcement trends, and compliance challenges arising from supply chains. The panel brings together leading practitioners from Europe and America to address this rapidly evolving enforcement area. Read more >>
ABA International White Collar Crime Institute White Collar Crime Hypothetical Exercise. Partner Nichloas C. Harbist will serve as a panelist at the ABA International White Collar Crime Institute, joining leading white collar practitioners for an interactive discussion based on real-world cross-border investigations and enforcement scenarios. The session will explore complex legal, compliance, and strategic issues that arise in international white collar matters. Read more >>
IBA Annual Conference Copenhagen 2026: “Uber Regulators: New Supervisors, Sanctions and Shenanigans.” Brad Henry will serve as Session Chair for the “Uber Regulators” panel at the IBA Annual Conference in Copenhagen on October 6, 2026, in his capacity as Chair of the IBA’s Anti-Money Laundering and Sanctions Expert Subcommittee. The session will examine how professional services firms are increasingly subject to reporting obligations and enforcement actions from general-purpose financial regulators and supra-national agencies. Notably, Carolin Gardner, Head of the European Banking Authority’s AML/CFT Unit, will join the panel as a special guest. Read more >>
© 2026 Blank Rome LLP. All rights reserved. Please contact Blank Rome for permission to reprint. Notice: The purpose of this update is to identify select developments that may be of interest to readers. The information contained herein is abridged and summarized from various sources, the accuracy and completeness of which cannot be assured. This update should not be construed as legal advice or opinion, and is not a substitute for the advice of counsel.+