Welcome to the May 2026 edition of the Jenner & Block Japan Newsletter, a publication containing updates about legal developments in the United States that may be noteworthy to our clients and other leaders in the Japanese legal and business communities.
First, we would like to highlight that the Jenner & Block Japan Practice was recently named again this year as one of five finalists for the Japan Practice Foreign Law Firm of the Year award—to be presented at the upcoming Asian Legal Business 2026 Japan Law Awards. This recognition honors foreign (non-Japanese) law firms that demonstrate exceptional legal service and substantial work involving Japanese elements despite not having physical offices in Japan, among law firms all over the world (not just those in the US). Japan Practice Co-Chair, Miwa Shoda, is planning to attend the award reception and dinner in Tokyo on Friday, June 12, and hopes to see many of you there.
This edition covers a wide range of legal and regulatory developments across multiple practice areas. We begin with an analysis of the Department of Justice’s (DOJ) recently announced first-ever Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy. We then examine new guidance issued by the Treasury Department’s Office of Foreign Assets Control on sham transactions and sanctions evasion. This is followed by a review of a recent unanimous decision by the Delaware Supreme Court that provides a clearer and more predictable framework for navigating transactions involving conflicted fiduciaries.
We continue with a summary of the White House’s National Policy Framework for Artificial Intelligence, which sets out legislative priorities across seven subject areas and represents the Administration’s clearest statement to date of its congressional ambitions. We also cover the DOJ’s intervention in a lawsuit brought by xAI challenging Colorado’s AI Act. Additionally, we provide an overview of Washington state’s newly enacted legislation, which bans virtually all non-compete agreements and significantly narrows the scope of permissible non-solicitation agreements. We then provide an overview of the Commodity Futures Trading Commission’s issuance of a no-action letter to a self-custodial crypto wallet developer. Finally, this edition concludes with a review of the DOJ Fraud Section’s 2025 Year-in-Review, which reveals an expanded enforcement blueprint signaling heightened regulatory risk and more aggressive corporate enforcement.
We hope that you find the information in the Jenner & Block Japan Newsletter of interest. We thank you for taking the time to review our publication.
Regards,
The Jenner & Block Team
Articles
Investigations, Compliance, and Defense
National Security and Crisis
The 50% Rule Is Dead; Long Live the 50% Rule
Corporate
Delaware Supreme Court Clears the Path for Conflicted Transactions
Artificial Intelligence
Takeaways from the White House's Framework for Artificial Intelligence
Artificial Intelligence
DOJ Joins xAI in Lawsuit Challenging Colorado AI Act
Noncompete
The Non-Compete Competition: Washington State's New Broad Ban on Non-Competes
Fintech and Crypto Assets
CFTC No-Action Letter for Self-Custodial Crypto Wallet Reflects Shift in Regulatory Approach
Investigations, Compliance, and Defense
DOJ Fraud Section 2025 Year-in-Review: Expanded Enforcement Signals Increased Corporate Risk
Related Attorneys
Related Capabilities
© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.