Key findings from investigations and enforcement trends in third quarter of 2025

Reed Smith partners Josh Love, Stephen Sessa, and Edward Shapiro have been recognized by Variety as elite lawyers in music for their outstanding leadership in music law, talent deals, and innovation within the entertainment industry.

In addition to individual accolades, Reed Smith has been ranked among the top law firms for mergers and acquisitions (M&A) and private equity by PitchBook. This recognition reflects the firm’s strong deal activity globally, highlighting their expertise and success in these areas.

Recently, a group of regulatory attorneys from Reed Smith came together to provide insights into the key trends expected in the third quarter of 2025. While the full webinar recording is available on demand, here are some key takeaways from the session:

Authorities are intensifying scrutiny and enforcement on emerging technologies and dual-use items, leading to increased regulatory attention in these sectors. Sanctions and tariffs, particularly those targeting Russia, Iran, North Korea, and China, are becoming more stringent, prompting businesses to enhance supply chain security and decrease reliance on high-risk regions. Customs enforcement is on the rise, with continued regulatory focus on valuation, classification, export controls, and sanctions, alongside growing expectations for increased scrutiny on country of origin issues.

Lessons learned from the Department of Justice’s 2025 National Health Care Fraud Takedown reveal a significant shift in the risk landscape. Transnational criminal organizations are expanding beyond narcotics, leveraging artificial intelligence for criminal activities. Organizations must update their risk assessments, utilize data effectively to prevent violations, and enhance due diligence procedures to adapt to this evolving threat environment.

The Securities and Exchange Commission (SEC) has renewed its focus on traditional securities fraud impacting retail investors, such as insider trading and market manipulation. There has been a shift in crypto regulation through enforcement, emphasizing the development of a policy framework around cryptocurrency and digital assets. The SEC is adopting a more registrant-friendly approach and offering increased negotiation opportunities.

In terms of cooperation, self-reporting, and deferred prosecution agreements with the UK Serious Fraud Office, the agency has introduced new guidance to enhance transparency and efficiency, aligning more closely with US Department of Justice standards. Companies now have a heightened incentive to self-report and fully cooperate, with stringent timelines for response and resolution. Expectations for cooperation have increased, requiring more evidence, transparency, and voluntary privilege waiver as a key indicator of cooperation.

As the DOJ’s pause on Foreign Corrupt Practices Act (FCPA) enforcement comes to an end, international companies must prepare for increased scrutiny. The DOJ will resume active FCPA enforcement, targeting cartels, transnational crime, fair competition, national security, and serious misconduct. While declinations are possible, companies should be prepared for enhanced enforcement efforts and stringent compliance requirements.