I was hanging out with my friend this weekend, both catching up on emails from a coffee shop. After a while, he turned to me. “Well sh*t. Looks like my social security number might be on the dark web.”...more
El 7/24/24, FinCEN actualizó su página de preguntas frecuentes sobre BOI (“Beneficial Ownership Information”) para incluir una pregunta nueva y una nueva actualización. FinCEN afirma que seguirá brindando orientación sobre...more
On 7/24/24, FinCEN updated its BOI FAQs page to include one new question and one new update. FinCEN states that it will continue to provide guidance on how to submit beneficial ownership information; including updating the...more
As discussed in our three prior client alerts, effective as of January 1, 2024, the Corporate Transparency Act (“CTA”) and rules issued thereunder by the Financial Crimes Enforcement Network (“FinCEN”) require most U.S....more
Every day, the Freedom of Information Act illuminates government practices by ensuring public access to federal records. It is the quintessential Sunshine Act and has been a key tool for ensuring government transparency since...more
In the digital age, identity theft has taken on new and sinister forms, extending beyond the living to the deceased. When a loved one passes away, their identity doesn’t simply vanish; it lingers in both the digital realm and...more
Consistent with an uptick in fraud in the trucking industry, a new scam email started making its rounds to motor carriers the week of July 29, 2024. The email, appearing to be from the Federal Motor Carrier Safety...more
Recently, I attended the 2024 Summer Meeting for the American College of Trust and Estate Counsel (ACTEC) in Toronto. While there I presented to ACTEC’s Digital Property Committee on ghost hacking. Ghost hacking is when a...more
Are you wondering when a US taxpayer should consider the IRS Voluntary Disclosure Program or VDP? Are you concerned about unreported or under-reported income, financial accounts, assets, investments, cryptocurrency or...more
On March 29, 2024, the Financial Crimes and Enforcement Network (FinCEN) in collaboration with the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the National Credit Union...more
Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more
On March 29, FinCEN published a request for information (RFI) and comment in the Federal Register, in consultation with the OCC, FDIC, NCUA, and the Fed, to receive more information on the Customer Identification Program...more
On March 28, 2024, the Financial Crimes Enforcement Network (FinCEN), in consultation with the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the National Credit Union Administration,...more
On March 20, the U.S. House of Representatives passed House Resolution 7520, the Protecting Americans’ Data from Foreign Adversaries Act of 2024, targeting companies that sell sensitive information to “foreign adversaries.” ...more
A U.S. district court in the Eastern District of New York recently denied a motion for summary judgment filed by a credit card issuer because the plaintiff alleged identity theft and a reasonable factfinder could determine...more
The FCC has significantly expanded telecommunications carriers’ data breach notification and reporting obligations. Telecommunications carriers, including Voice over Internet Protocol (VoIP) services, and telecommunications...more
On March 21, 2023, Virginia Governor Glenn Youngkin signed SB 1040 into law. The new law, which goes into effect on July 1, 2023, prohibits employers from using an employee’s social security number or any derivative thereof...more
On March 21, 2023, Virginia’s governor approved Senate Bill 1040, which prohibits an employer from using an employee’s social security number or any derivative as an employee’s identification number. The bill also prohibits...more
Virginia has enacted two new laws which will further limit employers’ use of nondisclosure and nondisparagement agreements with employees and prospective employees and will bar the use of social security numbers as employee...more
De acuerdo con el IRS y FinCEN, los casinos con licencia para hacer negocios como casinos y que tienen ingresos brutos anuales de juego superiores a $1,000,000 son instituciones financieras sujetas a los requisitos de la Ley...more
On January 1, 2023, Virginia’s Consumer Data Protection Act (CPDA) takes effect. Key features of the CPDA include expansive consumer privacy rights (right to access, right of rectification, right to delete, right to opt-out,...more
A group of 40 AGs reached settlements with Experian Information Solutions, Inc. and T-Mobile USA, Inc. concerning a 2015 data breach experienced by Experian that allegedly compromised the personal information of more than 15...more
The trusts maintained to hold assets of ERISA plans are separate tax entities from the employers sponsoring the plans. Therefore, each is required to have its own federal tax ID number. Knowing when and where to use whose EIN...more
When it began in 1996, the E-Verify program initially was available in only five states. Currently, more than 520,000 employers nationwide use the program, with almost 44,000 of those being federal contractors. Because...more
Whether because of the tight U.S. labor market or flawed onboarding processes, many undocumented workers are becoming participants and accruing benefits in ERISA-governed employee benefit plans. Dealing with such plan...more