News & Analysis as of

F-1 Optional Practical Training Proposed Rule Released; Work Authorization Expanded for STEM Students

The long-awaited proposed rule on F-1 Optional Practical Training (OPT) was published in the Federal Register on October 19, 2015, by the U.S. Department of Homeland Security (DHS). The proposed rule is titled “Improving and...more

AML Update: The Rumors Are True – FinCEN Proposes Regulations That Will Require SEC Registered Investment Advisers to Adopt an AML...

On September 1, 2015, the Financial Crimes Enforcement Network (“FinCEN”) published in the Federal Register long-rumored proposed regulations that will require Securities and Exchange Commission (“SEC”)-registered investment...more

FinCEN Proposed AML Rule For Investment Advisers

The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of Treasury, issued a proposed anti-money laundering rule applicable to investment advisers registered with the U.S. Securities and Exchange...more

Understanding CIPs, Builder’s Risk, and Inland Marine Insurance Policies

Part of Bradley Arant’s Policyholder Insurance Coverage Team’s six-part Maximize Your Company's Insurance Coverage Webinar Series, the “Understanding CIPs, Builder’s Risk, and Inland Marine Insurance Policies” webinar, led by...more

Proposed AML Regulations for Registered Investment Advisers Released by FinCEN

On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released proposed rules that would require investment advisers that are registered or required to be registered (RIAs)...more

FinCEN Proposes New Anti-Money Laundering Rule For Investment Advisers

On August 25, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM), which would impose anti-money laundering (AML), suspicious activity reporting,...more

FinCEN Proposes Anti-Money Laundering Rules for Registered Advisers

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) on August 25, 2015 proposed rules to require SEC- registered investment advisers to adopt and maintain anti-money laundering (AML) programs and to...more

FinCEN Proposes AML Program Rule for Investment Advisers

The Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule that would subject certain investment advisers to AML requirements under the Bank Secrecy Act (the BSA). In proposing the rule, FinCEN cited...more

Alert: Seven Steps To Prepare For The New Gainful Employment Rule

The Gainful Employment Rules became effective on July 1, 2015, and you probably already know that your institution has a deadline to report six years' worth of institutional, student and financial data to the Department of...more

FERC, NERC and Business Blackout: New CIP Standards and Fictional Cyber Attacks

The Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (NOPR) July 16, 2015, proposing to approve various Critical Infrastructure Protection (CIP) reliability standards proposed by the North...more

Lloyd’s Report Highlights Risk of Cyberattacks on National Power Grid

A sophisticated cyberattack on the U.S. power grid could cause nearly $250 billion in economic losses and, under the most severe circumstances, cost more than $1 trillion to the U.S. economy, according to a recent report...more

FinCEN Proposes New Rule Requiring Identification of Beneficial Owners

This summer the Financial Crimes Enforcement Network ("FinCEN”) issued a notice of proposed rulemaking proposing a rule that, if adopted, would mandate that financial institutions require their legal entity customers to...more

Beware of the CIP—Parent Applications Can Be Prior Art

Companies file patent applications with the United States Patent and Trademark Office (USPTO) to protect promising innovations. Often, however, improvements, additional uses and refinements surface after filing a patent...more

FinCEN Proposes Customer Due Diligence Rule

On July 30, FinCEN released a proposed rule that would amend BSA regulations to clarify and add customer due diligence (CDD) obligations for banks and other financial institutions, including brokers or dealers in securities,...more

The Empire State Strikes Back: New York Proposes Rules for Virtual Currency

The New York State Department of Financial Services (the “Department”) recently published its proposed rules and regulations (the “Proposed Rules”) for vendors conducting business involving virtual currency. The Proposed...more

IRS Announces New Program to Audit Section 409A Compliance

Internal Revenue Code Section 409A (Section 409A) governs the federal income tax treatment of non-qualified deferred compensation and retirement plans and arrangements. Employer noncompliance in both documentation and...more

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