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Investigation and Disclosure Best Practices

Client Alert | 1 min read | 06.06.16

In Importance of Disclosures and Cooperation During and After Internal Investigations, Crowell & Moring attorneys review several recent regulatory changes and highlight the growing importance of targeted communication with the government before, during, and after internal investigations. Among other things, the article lists suspension and debarment statistics taken from the System for Award Management for the first half of fiscal year 2016 to demonstrate the importance of, and benefits that may be achieved from, targeted communication to the government by experienced government contracts investigations attorneys.

Insights

Client Alert | 3 min read | 07.18.25

Eighth Circuit Cancels Click-to-Cancel

On July 8, 2025, the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) Negative Option Rule, also known as the Click-to-Cancel Rule, on procedural grounds. The Click-to-Cancel Rule, which provided a streamlined path for consumers to cancel subscription services in a few clicks of a mouse, was scheduled to take effect on July 14, 2025, but the Court found that the FTC had failed to follow mandatory procedural requirements....