Federal agencies and courts produced a dense stretch of activity heading into the week of October 19, with the Justice Department filing new suits against state and local governments, the Treasury Department announcing a record bank penalty and a fresh round of Iran-related sanctions, and the Supreme Court acting on an emergency application tied to the November elections. This briefing draws on primary records published by the agencies involved. Where a matter is pending, the allegations are those of the government and have not been adjudicated.
Government
Treasury announces more than $1.21 billion in penalties against Bank of America
The Treasury Department said on October 13 that it had reached enforcement actions totaling more than $1.21 billion against Bank of America. According to Treasury, the package includes a $1.2 billion penalty from FinCEN, a $750 million civil money penalty from the Office of the Comptroller of the Currency, and an $11.6 million settlement with OFAC over 475 apparent sanctions violations. Treasury describes the combined action as the third-largest penalty in its history and the largest in OCC history.
The release states that under the FinCEN consent order the bank admitted it willfully violated the Bank Secrecy Act, including by failing to maintain a compliant anti-money-laundering program and to file suspicious activity reports on time. Treasury says more than $5 billion in suspicious transactions were not timely reported. The required remedies include a third-party lookback and independent reviews of monitoring and due diligence systems. Readers should note that the figures above are Treasury’s characterizations of the consent orders.
Treasury and IRS propose Premium Tax Credit verification rules
On October 14, Treasury and the IRS issued proposed regulations implementing changes to the Premium Tax Credit. According to the release, the rules would begin in 2027, limit eligibility to U.S. citizens, nationals and certain lawfully present noncitizens, and add verification requirements for advance payments. Treasury Secretary Scott Bessent said the aim is to keep the credits reserved for eligible Americans.
The department also cited figures from the Centers for Medicare & Medicaid Services, saying more than 760,000 unverified enrollees were removed from Affordable Care Act rolls. Those figures are CMS’s and were not independently verified here. Because the measure is a proposed rule, it remains subject to public comment, and companion changes to Exchange procedures are expected from HHS.
Justice Department and HHS-OIG create a single path for health care fraud self-disclosure
The Justice Department’s National Fraud Enforcement Division and the HHS Office of Inspector General announced a self-disclosure protocol on October 15. Under it, a company that reports potential criminal health care misconduct to the Fraud Division can receive the benefits of both DOJ’s Corporate Enforcement Policy and the HHS-OIG protocol without a separate submission. The release adds that disclosing only to HHS-OIG generally does not count as a voluntary self-disclosure to DOJ.
Assistant Attorney General Colin McDonald said there is now “one clear point of contact.” For compliance officers at providers and vendors, the practical effect, according to the announcement, is that criminal matters belong with the Justice Department rather than the inspector general’s portal.
President signs three bills into law
The White House reported that the President signed S. 240, S. 283 and S. 2403 on October 15. S. 240 amends the Crow Tribe Water Rights Settlement Act of 2010 to allow more flexibility in completing water projects in Montana. S. 283, the Illegal Red Snapper and Tuna Enforcement Act, directs the Commerce Department to create a chemistry-based method for identifying the country of origin of seafood. S. 2403, the Retire through Ownership Act, amends ERISA to define adequate consideration for certain closely held stock.
The measures are modest in scope, but the seafood provision may matter to domestic fishers and importers, since it points to a standardized testing approach rather than paperwork-only verification.
Courts
Supreme Court grants stay in FCC v. Brown
The Supreme Court acted on an election-season dispute over broadcast advertising rates. According to SCOTUSblog’s case page, the Court on October 14 granted the FCC’s application (No. 26A476) 7-2, with Justices Sotomayor and Jackson indicating they would have denied it. Chief Justice Roberts had earlier entered an administrative stay on October 8 of a Fourth Circuit judgment dated October 7.
The underlying question, as summarized by a Wiley legal alert, is whether the lowest unit charge that Section 315(b)(1) of the Communications Act guarantees to candidates extends to authorized committees, joint fundraising committees and certain coordinated party advertising. The stay lasts pending any petition for certiorari. The merits are unresolved, and the filings should be consulted directly for the Court’s reasoning.
Justice Department sues St. Paul and Portland over mask and ID rules
On October 15 the Justice Department filed complaints against St. Paul, Minnesota, and Portland, Oregon, challenging local provisions that bar federal officers from wearing masks and require identification. Associate Attorney General Stanley Woodward cited the Supremacy Clause. The release lists similar recent suits in several other jurisdictions and does not name the court in which these were filed.
The cities have not been quoted in the release. Municipalities typically defend such measures as exercises of local police power, and the outcome will turn on how courts weigh intergovernmental immunity. This is a pending dispute, and neither side’s position has been tested.
Health care software owner sentenced to 19 years
The Justice Department reported that Brett Blackman, 43, of Johnson County, Kansas, was sentenced to 19 years in prison on October 14 for a scheme involving false doctors’ orders for orthotic braces. According to the release, claims exceeded $1 billion and Medicare and other insurers paid more than $450 million. A jury convicted him after a 23-day trial that ended in April 2026. Restitution and forfeiture have not yet been set.
Sixteen charged in illegal voting cases across three districts
The department announced charges involving 16 people on October 16, in the Eastern District of North Carolina, the Northern District of New York and the District of Idaho. The charges include voting by an alien and false claims of citizenship. The release notes that charging documents contain only accusations and that defendants are presumed innocent. Several defendants are described as lawful permanent residents.
Additional court and enforcement items
The department also announced a joint complaint with the FTC against REPS & Company and three executives in the Southern District of California, alleging violations of the BOTS Act and the FTC Act; the release says the claims are allegations only. A separate settlement with Cloudera includes a two-year PERM debarment, a $1.4 million back-pay fund and $600,000 in civil penalties.
International
Treasury targets Iranian financial networks under Operation Economic Outcast
On October 15 Treasury announced sanctions on an Iraqi bank, two Iranian offshore banks, a Dubai-based oil trustee and shadow-banking operators, as part of an operation first announced on August 24. Most designations were made under Executive Order 13902. Secretary Bessent said “the noose is tightening around Iran’s economy.” The department warned of possible secondary sanctions on foreign financial institutions that knowingly facilitate significant transactions for designated persons.
A companion action from FinCEN, described in a separate release, issued an alert asking financial institutions to watch for alleged diversion of religious charity funds, including khums payments, to the Iranian regime. The release stresses that legitimate charities should retain access to financial services. The allegations are Treasury’s.
State Department sanctions Cuban bank over alleged Iran links
The State Department sanctioned Banco Internacional de Comercio S.A. (BICSA), a Cuban state-owned bank, on October 15. According to the statement, BICSA has provided services since at least 2022 to Iran’s Karafarin Bank, which Treasury sanctioned in 2020. The designation was made under Section 2(a)(i)(A) of Executive Order 14404. Secretary Rubio said the United States “will not tolerate a rogue state hosting hostile foreign military, intelligence and terror operations.”
Treasury sanctions Cartel del Noreste network tied to horse racing
OFAC on October 13 sanctioned four individuals and 11 entities linked to Cartel del Noreste, a designated Foreign Terrorist Organization. Treasury alleges the network used American Quarter Horse racing and construction contracts to launder proceeds and alleges one trucking firm originated cocaine shipments totaling 52 kilograms. Treasury says the action was coordinated with U.S. law enforcement and Mexico’s financial intelligence unit. These are Treasury’s allegations, and the named parties have not been shown to have responded in the release.
Rubio travels to Central Asia and India
The State Department said Secretary Rubio will travel October 17-22 to Samarkand, Uzbekistan, for the C5+1 Ministerial, and then to Mumbai and Jamnagar, India. The department says he will lead a commercial delegation of more than 200 business leaders in Uzbekistan and discuss energy cooperation in India.
Worth Watching
California voter-list suit. The Justice Department’s October 15 complaint against California alleges that more than 20,000 likely noncitizens are registered to vote. DHS describes its findings as preliminary. Watch for California’s formal response and any motion practice. The state’s position was not included in the release, and the claims remain unproven.
Rubio in Samarkand. The C5+1 Ministerial and business delegation run through this week, and any announced commercial agreements will be a measure of the trip’s results.
Landau in South America. Deputy Secretary Christopher Landau is scheduled to travel October 19-26 to Paraguay and Argentina, with a trade delegation in Asuncion and meetings in Buenos Aires on the Andes-Atlantic Corridor.
Supreme Court. The Court’s October argument calendar, per its hearing list, ran through October 14. Watch the docket for orders and any certiorari petition in FCC v. Brown.
Local-law preemption suits. Responses from St. Paul and Portland to the Supremacy Clause complaints will show how the cities intend to defend their ordinances.
Right of reply: The Investigative Journal welcomes responses from any party named in this briefing. Contact the newsroom at tij.news. All government allegations described above remain unproven unless a court has ruled otherwise.