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Proposed Expansion of CFIUS Poses Increased Risks to U.S. Real Estate Investors and Operators

On July 19, 2024, the U.S. Department of the Treasury published a Proposed Rule after first issuing a Notice of Proposed Rulemaking on July 8. The rule seeks to expand the jurisdiction that the Committee on Foreign Investment...more

U.S. Economic Sanctions Against Russia Grow Amid the Ukraine Crisis: What Businesses Need to Know (UPDATED)

Originally Published: February 25, 2022 – Updated: May 16, 2022 U.S. economic sanctions against Russian interests continue to build in response to the developing situation between the Russian Federation and Ukraine. Donetsk...more

U.S. Economic Sanctions Against Russia Grow Amid the Ukraine Crisis: What Businesses Need to Know (UPDATED)

Originally Published: February 25, 2022 – Updated: April 18, 2022 - U.S. economic sanctions against Russian interests continue to build in response to the developing situation between the Russian Federation and Ukraine. ...more

U.S. Economic Sanctions Against Russia Grow Amid the Ukraine Crisis: What Businesses Need to Know (UPDATED)

Originally Published: February 25, 2022 – Updated: March 25, 2022 - U.S. economic sanctions against Russian interests have been building in response to the developing situation between the Russian Federation and Ukraine. ...more

U.S. Economic Sanctions Against Russia Grow Amid the Ukraine Crisis: What Businesses Need to Know (UPDATED)

Originally Published: February 25, 2022 – Updated: March 15, 2022 U.S. economic sanctions against Russian interests have been building in response to the developing situation between the Russian Federation and Ukraine....more

U.S. Economic Sanctions Against Russia Grow Amid the Ukraine Crisis: What Businesses Need to Know (UPDATED)

Originally Published: February 25, 2022 – Updated: March 8, 2022 U.S. economic sanctions against Russian interests have been building in response to the developing situation between the Russian Federation and Ukraine....more

OFAC Speaks Again on Ransomware: Mature Cybersecurity Programs Are Important

Last year, as employees clicked away at home amid the COVID-19 pandemic lockdown, ransomware attacks surged, with hospitals and other health care providers the top target. This year will be worse—2021 has already seen more...more

An Intersection Between Ransomware and U.S. National Security: OFAC Speaks

Picture this: At some point in the next six months, you lose access to your files. Even worse, your company loses access to its files. And you are told that if you want access to them again, you will have to pay a sizable...more

Federal Banking Agencies Issue BSA/AML Enforcement Guidance

On August 13, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Office of the Comptroller of the Currency (collectively, the...more

Bank Secrecy Act Compliance Issues for Small-Business Lending Under the CARES Act

With many banks and credit unions electing to limit Paycheck Protection Program (PPP) loans to existing customers, many nonbank lenders are scrambling to fill the gap and take part in the $349 billion program prior to the end...more

Need-to-Know Developments in Compliance, Investigations and White Collar Defense

We hope this alert finds you, your families and your colleagues healthy and safe in these challenging times. The professionals in Manatt’s investigations, compliance, strategic response and white collar defense practices...more

BSA/AML News: FinCEN Remarks, New Bill

In Bank Secrecy Act and anti-money laundering (BSA/AML) news, a bipartisan group of lawmakers introduced a bill aimed at updating AML laws that would require companies to disclose their true owners at the time of...more

Regulators Reveal “Secret Sauce” on BSA/AML Exams

Shining the light on previously undisclosed examination practices, federal banking regulators and other entities issued an important joint statement addressing their risk-focused approach to BSA/AML examinations....more

Innovation Oversight: From the DFS to FinCEN to Lawmakers

In regulatory oversight news, the New York Department of Financial Services (DFS) announced the creation of a new Cybersecurity Division and the Financial Crimes Enforcement Network (FinCEN) launched an Innovation Hours...more

Operation Choke Point Lawsuit Comes to an End

Putting an end to a 2014 lawsuit filed by payday lenders challenging the actions of federal regulators in Operation Choke Point, the Federal Deposit Insurance Corporation (FDIC) announced a resolution to the action....more

Federal Reserve, FDIC Enforcement Efforts

In recent enforcement actions, the Board of Governors of the Federal Reserve System announced an order with a Japanese bank over weaknesses with respect to its New York branch’s Bank Secrecy Act / anti-money laundering...more

From SEC to FinCEN Enforcement Everywhere

Reminding financial institutions that a multitude of enforcers are at their doorstep, the Securities and Exchange Commission (SEC) announced a $3 million deal with an online lender....more

Second Circuit: Tribal Officials Must Face Suit

The U.S. Court of Appeals, Second Circuit has ruled that an online tribal lender must comply with state interest rate and licensing laws, allowing a pair of borrowers to move forward with their suit against tribal officials....more

FAA Proposes New Rules Expanding Drone Operations Over People and at Night

On January 14, 2019, Secretary of Transportation Elaine Chao announced that the Federal Aviation Administration (FAA) would be publishing in the Federal Register a Notice of Proposed Rulemaking (NPRM) that proposes to permit...more

U.S. Sanctions Enforcement Against Foreign Financial Institutions Continues

While major enforcement actions against foreign banks for U.S. sanctions violations appear to have ebbed over the past three years, the recent settlement of sanctions-related claims, which included imposition of $1.34 billion...more

Latest BSA/AML Penalty: $100M From OCC

On October 23, 2018, the Office of the Comptroller of the Currency (OCC) assessed a $100 million civil money penalty against a national bank primarily known for its issuance of credit cards, for failing to comply with a 2015...more

New Pilot Program Regulations Expand CFIUS’ Reach

On October 10, 2018, the Department of the Treasury issued a set of interim regulations (31 C.F.R. Part 801) to implement certain provisions of the Foreign Investment Risk Review Modernization Act (FIRRMA), signed into law by...more

FAA Approves First Radar-Assisted BVLOS Drone Operations

Shortly after President Trump signed the FAA Reauthorization Act of 2018 on October 5, which among other initiatives calls for the Federal Aviation Administration (FAA) to develop regulations to permit unmanned aircraft...more

FAA Reauthorization Act Authorizes Major Expansions in Drone Operations

On October 5, 2018, President Donald Trump signed into law the FAA Reauthorization Act of 2018, which funds the Federal Aviation Administration (FAA) for the next five years. In addition to a variety of security and safety...more

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