Key point: The investigative sweep is part of a growing multistate approach to privacy enforcement actions.

On September 9, the California Privacy Protection Agency (CPPA) announced that it has initiated a joint regulatory sweep in collaboration with attorneys general (AG) from California, Colorado, and Connecticut. The sweep will target businesses’ compliance with legal requirements associated with recognition of opt-out preference signals (OOPS) and universal opt-out mechanisms (UOOMs) that consumers can use to exercise their right to opt out of online tracking technologies (i.e., targeted advertising, sales, or sharing).

The Federal Trade Commission (FTC) and the Utah Department of Commerce’s Division of Consumer Protection (Division), represented by the Office of the Utah Attorney General (AG), recently announced a proposed consent order with Aylo, the company that owns and operates pornography websites, including Pornhub.com and Redtube.com. The proposed consent order includes the implementation of a compliance program and a $5 million penalty.

What Happened

Last week, Colorado lawmakers held a special session that culminated in a decision to delay the implementation of the Colorado Artificial Intelligence Act (CAIA) until June 30, 2026, extending the timeline beyond its original February 2026 start date. That delay gives businesses a brief window to prepare, but the law remains in effect, requiring companies to build governance programs and perform regular impact assessments of high-risk AI systems.

On August 29, 2025, during a speech at Ohio State University Law School, Assistant Attorney General Gail Slater announced the creation of a “Comply With Care” task force within the Antitrust Division of the Department of Justice (DOJ), which will focus on enforcement actions against parties flouting disclosure obligations. The speech and task force are a continuation of the Antitrust Division’s recent lawsuits against companies for failing to make merger filings under the Hart-Scott-Rodino (HSR) Act or responding properly to investigations.

Summary

On August 29, 2025, the U.S. Department of Justice (DOJ) announced the formation of a cross-agency Trade Fraud Task Force in partnership with the Department of Homeland Security (DHS). This initiative is designed to strengthen enforcement against importers and other parties who seek to defraud the U.S. by evading tariffs, duties, and other trade regulations. The Trade Fraud Task Force is focused on ensuring compliance with trade laws, including all applicable tariffs and duties, such as antidumping and countervailing duties, as well as Section 301 tariffs on Chinese-origin goods. The task force will leverage resources and expertise from both DOJ’s Civil and Criminal Divisions, and DHS agencies, including U.S. Customs and Border Protection (CBP), and Homeland Security Investigations (HSI).

On August 28, 2025, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) published a rule relaxing certain restrictions on Syria under the Export Administration Regulations (EAR). But unlike the much broader lifting of U.S. sanctions on Syria, which we previously discussed, BIS has retained significant parts of the longstanding restrictive export control regime on Syria.

Spencer Churchill, an associate based in Troutman Pepper Locke’s Washington, D.C. office, has been appointed to serve as a deputy assistant attorney general in the Department of Justice’s (DOJ) Office of Legal Counsel (OLC). In his new position, he will advise on some of the most important and complex legal questions surrounding executive power and agency action. The OLC counsels the president and executive branch agencies on the parameters of their constitutional and statutory authority, reviews all executive orders, drafts legal opinions of the attorney general, and comments on the constitutionality of pending legislation.

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Thursday, September 25 • 1:00 – 3:10 p.m. ET

Sadia Mirza, co-leader of Troutman Pepper Locke’s Incidents + Investigations practice, Privacy + Cyber Partner Timothy St. George, and Regulatory Investigations, Strategy + Enforcement Counsel Gene Fishel, will participate in an upcoming CLE with myLawCLE to examine the nuances of navigating cybersecurity breaches.

In this episode of our special Regulatory Oversight: Solicitors General Insights series, RISE Counsel Jeff Johnson, a former deputy solicitor general in the Missouri Attorney General’s office, welcomes Michigan Solicitor General Ann Sherman and New Jersey Solicitor General Jeremy Feigenbaum. They explore the art of oral advocacy, sharing insights into how they effectively present cases. The conversation also addresses state sovereignty, emphasizing the importance of allowing states to experiment with policies and the impact of bipartisan issues, particularly those that resonate most effectively in front of SCOTUS.