On December 16, 2025, the Federal Trade Commission announced an enforcement action against Illusory Systems Inc., a Utah-based company doing business as Nomad, following a major data breach in which hackers stole $186 million from consumers.
On December 19, 2025, the European Commission announced the renewal of the two UK adequacy decisions originally adopted in 2021, reaffirming that personal data may continue to move freely between the European Economic Area and the UK.
In recent months, some companies have begun reconsidering their sustainability targets. This trend is influenced by a range of factors, including economic pressures and scrutiny of climate action by the current federal administration and state attorneys general. In addition, many companies with interim decarbonization goals (e.g., companies with “net zero by 2050 goals” that also set 2030 targets) are finding they are not on track to meet them. When considering revising or abandoning existing goals, it is important to consider emerging risks under the current legal landscape, and to develop and follow a deliberate strategy to mitigate those risks.
EPA’s Office of Enforcement and Compliance Assurance (OECA) recently announced a major shift in the agency’s approach to environmental enforcement, emphasizing swift, efficient achievement of compliance over punitive or expansive enforcement measures. The “Reinforcing a ‘Compliance First’ Orientation for Compliance Assurance and Civil Enforcement Activities” memo (not publicly available as of this writing) clarifies that EPA’s primary goal is to ensure compliance with federal environmental laws using the most defensible and clear interpretations of statutory or regulatory mandates, thereby reducing ambiguity and regulatory uncertainty to industry’s benefit. The memo has implications for future compliance and enforcement activity as well as ongoing cases.
The United States Occupational Safety and Health Administration (“OSHA”), does not have a safety standard specifically addressing extreme weather. Instead, OSHA relies on the General Duty Clause of the Occupational Safety and Health Act to address identified hazards to workers in extreme weather. The General Duty Clause requires employers to provide employees “a place of employment which [is] free from recognized hazards that are causing or are likely to cause death or serious physical harm.”
