News & Analysis as of

U.S. Treasury Compliance

Dechert LLP

Highlights from the CFIUS Annual Report

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The U.S. Department of the Treasury’s Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) has published its Annual Report to Congress for 2023 (the “Annual Report”), which provides important data...more

Proskauer - Regulatory & Compliance

Treasury Department Moves to Expand CFIUS’s Real Estate Jurisdiction & Implement China-Bound Tech Investment Restrictions

The U.S. Department of the Treasury (Treasury), as Chair of the Committee on Foreign Investment in the United States (CFIUS), has announced a proposed rule to expand CFIUS’s jurisdiction over real estate transactions by...more

Freiberger Haber LLP

Enforcement News: SEC Charges Bank With Misleading Investors About The Strength Of Its BSA/AML Compliance Program And Its...

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The Currency and Foreign Transactions Reporting Act, also known as the “BSA,” enacted in 1970, established requirements for record-keeping and reporting by banks and other financial institutions. The BSA is designed to, among...more

Holland & Knight LLP

Treasury Department Confirms Suspension of U.S.-Russia Income Tax Treaty

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The U.S. Department of the Treasury on June 17, 2024, confirmed it had formally notified Russia about the suspension of the Convention between the United States of America and the Russian Federation for the Avoidance of...more

PilieroMazza PLLC

Weekly Update for Government Contractors and Commercial Businesses – June 2024 #4

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Construction Industry Wage-and-Hour Issues: 6 Tips for Laying a Foundation of Compliance - The construction industry feeds a significant part of the U.S. economy, providing millions of short- and long-term jobs across the...more

Holland & Knight LLP

OFAC Expands Secondary Sanctions Targeting FFIs Transacting with Sanctioned Russian Persons

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Nearly six months after President Joe Biden signed an executive order (EO) authorizing secondary sanctions against Foreign Financial Institutions (FFIs) conducting or facilitating significant transactions with certain...more

Venable LLP

CFIUS Proposes Increased Penalties for Noncompliance and Updated Mitigation and Enforcement Rules

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As the lead agency for the Committee on Foreign Investment in the United States (CFIUS or the Committee), the U.S. Department of the Treasury released new proposed rules on April 11, 2024 intended to enhance the enforcement...more

Latham & Watkins LLP

FCA and PRA Publish Final Securitisation Rules: Key Points

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Firms will need to update their internal procedures and ensure they are ready to comply with the new requirements ahead of 1 November 2024. HM Treasury (HMT), the Financial Conduct Authority (FCA), and the Prudential...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - April 2024

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, specifically...more

BakerHostetler

Key Sanctions Developments During the First Quarter of 2024

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During the first quarter of 2024, there were significant developments in the U.S. sanctions framework. This report summarizes the key developments and provides links to the relevant sources....more

Pillsbury Winthrop Shaw Pittman LLP

Non-U.S. Companies on Alert: U.S. Government Issues Tri-Seal Compliance Note on Global Enforcement

New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more

Cozen O'Connor

U.S. District Court for the Northern District of Alabama Finds CTA Unconstitutional: National Small Business United, et al v....

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In a case brought by the National Small Business Association and an individual owner of a small business (Plaintiffs), the U.S. federal district court for the Northern District of Alabama has ruled that the Corporate...more

Morrison & Foerster LLP

Tri-Seal Compliance Note Stresses Importance of Non-U.S. Persons Complying with U.S. Sanctions and Export Control Laws

On March 6, 2024, the U.S. Departments of Commerce, Justice, and the Treasury issued a Tri-Seal Compliance Note (Compliance Note) stressing the need for non-U.S. persons to comply with U.S. sanctions and export controls. The...more

American Conference Institute (ACI)

Industry Responses to the U.S. Outbound Investment Regulatory Regime

The only thing truly certain about the proposed U.S. outbound investment regulatory regime is that a lot of uncertainty remains. But industry responses garnered during the comment period may, at least partly, foretell the...more

ArentFox Schiff

Investment Advisers To Be Subject to Strengthened AML Regulations Under FinCEN’s Proposed Rule

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On February 13, the US Department of the Treasury’s (USDT) Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) which, if adopted, would sweep Security and Exchange Commission-Registered...more

Dechert LLP

Department of the Treasury’s CDFI Fund Releases Revised Certification Application

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The U.S. Department of the Treasury’s Community Development Financial Institutions Fund released an updated Community Development Financial Institution (CDFI) Certification Application (Application). This updated...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

ACA-Required Coverage of Contraceptive Care Remains Agency Focus

Once again, the U.S. Departments of Labor, Health and Human Services, and the Treasury have issued guidance on the Affordable Care Act’s (ACA) required coverage of contraception without cost sharing, clarifying the permitted...more

Mayer Brown

Russia/Ukraine Sanctions Update - Month of February

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I. US SANCTIONS - US Department of the Treasury Sanctions Almost 300 Individuals and Entities: On February 23, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned almost 300 individuals...more

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

BCLP on

On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more

The Volkov Law Group

Sterling Bank’s ex-General Counsel hit with OCC Cease-and-Desist over Longstanding BSA/AML Shortcomings

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The Treasury Department’s Office of the Comptroller of the Currency (“OCC”) has taken action against the former General Counsel of Michigan-based Sterling Bank and Trust in the agency’s latest action against an individual...more

Mintz Edge

New for 2024: Compliance with the Corporate Transparency Act Necessary for Many Mintz Client

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Clients with Limited Liability Companies, Corporations, and Other Entities Likely Impacted - Reporting requirements under the Corporate Transparency Act (CTA) are in effect beginning January 1, 2024. Under the CTA,...more

Snell & Wilmer

CFIUS & Export Controls: The Foreign Investment Regulations Putting Buyers, Sellers, and M&A Practitioners at Risk

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In recent memory, enforcement of the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) regulations has been mostly limited and sporadic. But recently, the U.S. government is reviving and...more

Dechert LLP

New Year's Resolution: Tackling Russian Sanctions Evasion

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Throughout December, the United States, European Union, and United Kingdom adopted a series of new sanctions packages against Russia that are expansive and multilayered and pose additional compliance challenges. The new...more

Holland & Knight LLP

FinCEN Issues Final Rule Implementing Access and Safeguard Provisions of the CTA

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The Corporate Transparency Act (CTA) was enacted in 2021 and became effective on Jan. 1, 2024. The CTA was passed with the aim of enhancing transparency in corporate ownership, so as to combat the proliferation of anonymous...more

Sunstein LLP

Tango Your Way to Government Compliance: The Corporate Transparency Act

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Why might a 255 foot yacht named “Tango” anchored in Mallorca make your life more complicated? Because its owner, Russian oligarch Viktor Vekselberg, had been sanctioned by the U.S. in 2018 for “contributing to the situation...more

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