FOIA Advisor

Court opinion issued Jan. 15, 2026

Court Opinions (2026)Allan BlutsteinComment

Leopold v. DOJ (D.D.C.) -- on remand from the D.C. Circuit, holding that DOJ properly relied on Exemption 8 to withhold a Monitor Report assessing HSBC’s anti–money laundering and sanctions compliance and met the foreseeable harm requirement because disclosure of any portion of the report would threaten the effectiveness of bank supervision; reasoning that although redactions could mitigate harms such as criminal exploitation, competitive injury, and chilled employee candor, those risks alone did not justify withholding the entire document; further explaining that DOJ showed—through sworn declarations from foreign regulators—that release of even a redacted report would undermine settled expectations of confidentiality and foreseeably chill future cooperation with U.S. monitors and regulators.

Summaries of published opinions issued in 2026 are available here. Earlier opinions are available for 2025, 2024, and from 2015 to 2023.