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Reporting Requirements Corporate Counsel

Baker Botts L.L.P.

OFAC Extends Recordkeeping Requirements for All Sanctions Programs

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In an era of active U.S. sanctions policy, it is not uncommon to see the Office of Foreign Assets Control (“OFAC”) issue a notice changing U.S. sanctions – promulgating a new sanctions program or updating the designation of a...more

Morrison & Foerster LLP

OFAC Extends Recordkeeping Requirements from Five to 10 Years; Issues Paperwork Reduction Act Request for Comments

On September 11, 2024, OFAC announced its Interim Final Rule to Extend Recordkeeping Requirements from Five to 10 Years. The Interim Final Rule (IFR) was published in the Federal Register on September 13, 2024. Public...more

Wiley Rein LLP

CMMC 2.0 Update: DOD Proposed Rule Introduces Standard Terms for Contracts Subject to CMMC 2.0, Including Yet Another 72-Hour...

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WHAT: The U.S. Department of Defense (DOD) just published the second of two proposed rules setting forth key requirements for its long-anticipated Cybersecurity Maturity Model Certification (CMMC) 2.0 program. The earlier...more

BCLP

CTA and Corporate Governance: A Quick Guide for Situations Where CTA Comes into Play

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The Corporate Transparency Act (“CTA”) was enacted by The U.S. Congress in January 2021 as a way to protect the United States financial system from being used for money laundering and other illicit activities....more

Perkins Coie

Corporate Transparency Act Midyear Update: Game-Changing FinCEN Guidance and What To Do To Meet Year-End Filing Obligations

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June marked the six-month milestone for the implementation of the Corporate Transparency Act (CTA)—the landmark anti-money laundering law requiring beneficial ownership reporting for U.S. companies that became effective on...more

Ballard Spahr LLP

CFPB: Confidentiality Agreements Can’t Deter Whistleblowers from Reporting Alleged Violations

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The CFPB warned on July 24, 2024,  that confidentiality agreements that employees of a company are required to sign likely violate federal law if those agreements imply that employees could face retaliation from their...more

Foley & Lardner LLP

Oops! My Company Failed To File Its EEO-1 Report; Now What?

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As we reported last month, the U.S. Equal Employment Opportunity Commission’s (EEOC) extended deadline to file a 2023 EEO-1 Component 1 report (for covered entities) was July 9, 2024. That date now behind us, what’s a company...more

Seyfarth Shaw LLP

Update: Governor Healey Signs Massachusetts Pay Transparency Bill into Law - July 31, 2024

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After an extended legislative process, pay transparency requirements are coming for Massachusetts employers. On July 24, 2024, the Massachusetts House and Senate passed a bill requiring employers with over 25 or more...more

Stikeman Elliott LLP

Sanctions Evasion: Canada Takes Aim with New FINTRAC Reporting Requirements for Reporting Entities

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Reporting entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) will soon be subject to a new requirement to report transactions suspected to be related to sanctions evasion to the...more

Hinshaw & Culbertson LLP

Updated FinCEN FAQs Provide Three Important Clarifications on Reporting Obligations Under the Corporate Transparency Act (CTA)

The Corporate Transparency Act (the CTA) went into effect earlier this year, although many uncertainties about the CTA's application still remain. To help remedy those uncertainties, the Financial Crimes Enforcement Network...more

Cooley LLP

SEC Reporting Implications for Publicly Traded Companies Impacted by CrowdStrike Defective Software Update

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There are a number of US Securities and Exchange Commission (SEC) reporting implications arising from the server-related outages caused by CrowdStrike’s defective software update on July 19, 2024, and their impacts on public...more

Fisher Phillips

Will the EEOC Start Collecting Pay Data Again? 5 Pointers for Employers as You Track This Development

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The federal government wants you to share employee pay data again, along with the demographic data you already submit on employee job titles, sex, and race/ethnicity. According to its July 5 regulatory agenda, the Equal...more

Morris, Manning & Martin, LLP

FinCEN Alert: Dissolution Before 2025 Won't Spare CTA Reporting Requirement

On July 8, 2024, FinCEN published additional FAQs regarding entities that have ceased to exist.  Unsurprisingly, entities that formally and irrevocably dissolved prior to the Corporate Transparency Act's effective date of...more

Paul Hastings LLP

U.S. Government Issues Proposed Rules in Significant Step to Restrict Outbound U.S. Investment in Chinese Technology

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On June 21, 2024, the Treasury Department released long-expected proposed regulations to curtail investments by U.S. persons (including investments by U.S. limited partners in non-U.S. pooled funds) and U.S.-controlled...more

Foodman CPAs & Advisors

CTA Fraud Alert From FinCEN

FinCEN has learned of fraudulent attempts to solicit information from individuals and entities who may be subject to reporting requirements under the Corporate Transparency Act (CTA). Scammers are on the hunt to steal...more

Mintz - Privacy & Cybersecurity Viewpoints

SEC Issues New Statement on Cybersecurity Incident Disclosure

Last week, Erik Gerding, Director of the SEC’s Division of Corporation Finance (the Division), issued a statement providing clarification regarding the disclosure of cybersecurity incidents by reporting companies. This...more

Fisher Phillips

EEOC Sues Employers for Not Filing EEO-1 Reports: 5 Steps You Should Take Before June 4 Deadline to Avoid Similar Fate

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In an unprecedented action, federal workplace law officials just filed suit against 15 employers in 10 states alleging that they failed to file their mandatory EEO-1 reports and asking the court to order the employers to do...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Enacts a New Digital Regime Regulating the Conduct of Major Tech Platforms

The Digital Markets, Competition and Consumers Act (DMCC or the Act), adopted on 24 May 2024, empowers the Competition and Markets Authority (CMA) to regulate the conduct of major tech platforms....more

Wiley Rein LLP

Darned if You Do, Darned if You Don’t: Recent Lessons from the SEC On Cyber Reporting

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The Security and Exchange Commission (SEC) Director of the Division of Corporate Finance, Erik Gerding, released a statement on May 21, 2024 that may have regulated entities scratching their heads about compliance and the...more

Sheppard Mullin Richter & Hampton LLP

California Supreme Court Confirms the “Knowing and Intentional” Standard of California’s Wage Statement Law Requires a “Knowing...

In Naranjo v. Spectrum Security Services, the case’s second appearance before the California Supreme Court in two years, the Supreme Court confirmed that an employer does not incur civil penalties for failing to report unpaid...more

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for April 2024

Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine: •The SEC’s first “Shadow Trading” trial; •SCOTUS’s...more

Holland & Knight LLP

CTA Heats Up with New FAQs, Government and Amicus Briefs and New Draft Legislation

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The Corporate Transparency Act (CTA) is the gift that keeps giving. As affected entities and their advisers struggle to determine whether they are subject to the beneficial ownership information (BOI) reporting provisions of...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Climate Disclosure Rules: Your Questions Answered

The Securities and Exchange Commission’s climate-related disclosure rules pose a host of issues for companies. Below are answers from Skadden’s SEC Reporting and Compliance and Environmental Groups to some of the questions...more

BCLP

CFTC’s Annual Enforcement Results: Another Blockbuster Year

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The Commodity Futures Trading Commission ("CFTC") recently released its enforcement results for Fiscal Year 2023 ("FY 2023"), which ran from October 1, 2022, through September 30, 2023. ...more

Skadden, Arps, Slate, Meagher & Flom LLP

Utah Becomes First State To Enact AI-Centric Consumer Protection Law

On March 13, 2024, Utah enacted the Utah Artificial Intelligence Policy Act (UAIP), which imposes certain disclosure requirements on entities using generative AI tools with their customers, and limits an entity’s ability to...more

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