We recently gathered a group of regulatory attorneys from across Reed Smith to provide a rundown of the key trends to watch for in Q2 2026. If you missed the webinar, you can access the recording on demand.

Please see a short summary of our top takeaways below and look out for an invite to the next installment of this quarterly series – we hope you can join us!

The EU Anti-Corruption Directive: New rules, new risks, and key differences with the UK Bribery Act

1. The new EU Anti-Corruption Directive entered into force on June 1, 2026. It establishes a common minimum framework of corruption offenses, sanctions, and enforcement measures across the EU, while allowing member states to maintain or adopt stricter rules.
2.  EU member states are required to transpose the Directive’s core provisions into their national laws by June 1, 2028, although they may implement the changes earlier.
3. Businesses should use this two-year implementation period to refresh their anti-corruption risk assessments and compliance programs, taking into account the Directive’s expanded catalog of offenses and the enhanced expectations around effective oversight and supervision.

The G7 Russia price cap: Enforcement year-in-review and what the next wave targets

1. The G7 Russia price cap regime is becoming increasingly fragmented, with the EU and UK lowering the crude cap while the U.S. cap remains unchanged, making multijurisdictional screening and compliance more complex.
2. Enforcement is moving beyond individual vessels to broader trading networks, with recent UK, EU, and U.S. action targeting tankers, ports, terminals, traders, insurers, logistics providers, and other participants across the Russian oil supply chain.
3. Companies should expect closer scrutiny of attestations, pricing records, and sanctions escalation processes, and should ensure contracts allow suspension or termination where credible sanctions concerns arise, not only where a designation has been confirmed.

U.S. export control enforcement: Recent developments

1. Export controls and sanctions remain a top enforcement priority for the U.S. government. Companies should ensure their compliance programs are designed to address their regulatory obligations, particularly when conducting business in high-risk countries such as China. In the event of a potential violation, voluntary self-disclosure should be considered to minimize the risk of potential enforcement actions.
2. Conducting business through distributors and third-party agents is risky. Companies should implement enhanced KYC due diligence, including requesting end-use and end-user information. This information should be collected even if the company’s products are EAR99 and do not typically require a license.
3. Employee training will always be key. Potential violations may be avoided through adequate employee training, including technology control plans that address how to handle controlled technical data and technology.

State AG privacy enforcement

1. Privacy enforcement is becoming more active and higher-stakes, with increasing penalties: earlier this year, the largest privacy penalty was $2.75 million. Just last month, the historic high ballooned to $12.75 million – a 300% increase.
2. Regulators remain focused on two broad enforcement issues: (1) whether companies are providing consumers with clear and conspicuous disclosures around the collection, sharing, and selling of consumer personal information; and (2) whether companies are honoring consumers’ requests to “opt out” of having their personal information collected, shared, or sold.
3. On the horizon: scrutiny of data brokers and enforcement of California’s Delete Act, which allows consumers to submit requests directing data brokers to delete their personal information.

SEC enforcement: Insider trading

1. The SEC’s enforcement program continues to message a “back to basics” approach, with leadership emphasizing it will focus on potential misconduct with the greatest harm to investors, even as the agency brought materially fewer original enforcement actions last year.
2. Retail fraud and insider trading remain core priorities, but technical, non-fraud violations continue to be charged, including recent settled actions involving late Schedule 13D filings and whistleblower-award waiver language.
3. The recent insider trading case filed in parallel by the DOJ and the SEC in Boston against more than two dozen individuals underscores the SEC’s continued focus on classic fraud investigations.

Managing risk of false statements in government procurements

1. The era of AI enforcement is here – the DOJ, data miners, and whistleblowers are leveraging advanced AI tools, and AI is becoming central to government procurement enforcement.
2. Increased DOJ resources for fraud and FCA investigations point to increased government procurement enforcement activity.
3. Companies should consider conducting targeted risk assessments; investing in proactive data analytics capabilities to identify and remediate risks; and analyzing contracts and representations to the government.

DOJ’s new corporate enforcement policy: What the three-path framework means for companies

1. Under the CEP, if a whistleblower makes both an internal report to a company and a whistleblower submission to the DOJ, the company can still qualify for a declination if it self-reports within 120 days of receiving the whistleblower’s internal report and meets other requirements.
2. The CEP and SDNY’s Corporate Enforcement and Voluntary Self-Disclosure Program (implemented a few weeks before the CEP) vary as to eligibility, incentives, and other key considerations.
3. If applicable, parallel DOJ and SDNY disclosures may be beneficial to take advantage of the different incentives.

State AG antitrust enforcement: Review of 2025 and trends for 2026

1. State AGs are now independent, frontline antitrust enforcers – no longer just junior partners to federal agencies. They rejected a major DOJ settlement in the ticketing industry, won a landmark jury verdict, and are challenging DOJ merger settlements in court. Companies must plan for dual-track enforcement.
2. Algorithmic pricing and AI-driven tools are a bipartisan enforcement priority. Rent-pricing software lawsuits (housing), meat processing data aggregation (agriculture), and new state legislation targeting price-setting technology signal that any company using algorithmic pricing or data aggregation should expect AG scrutiny.
3. New state premerger notification laws in Colorado, Washington, and potentially other states mean merging parties face additional regulatory hurdles. Companies must incorporate state AG outreach into deal planning from the outset, as states have shown willingness to block or challenge mergers independently of federal clearance.