The Supreme Court has heard oral argument in a case to determine whether the Trump administration’s sweeping tariff regime, imposed under the International Emergency Economic Powers Act (IEEPA), is lawful. ...more
11/7/2025
/ Appeals ,
Constitutional Challenges ,
Court of International Trade ,
Executive Powers ,
International Emergency Economic Powers Act (IEEPA) ,
Learning Resources Inc v Trump ,
Non-Delegation Doctrine ,
Oral Argument ,
SCOTUS ,
Statutory Interpretation ,
Tariffs ,
Trump Administration ,
US Trade Policies
On October 9, 2025, the Financial Crimes Enforcement Network (FinCEN), along with the banking and credit union regulators, issued guidance in the form of frequently asked questions (FAQs) addressing the regulatory...more
10/15/2025
/ AML/CFT ,
Bank Secrecy Act ,
BSA/AML ,
Credit Unions ,
Currency Transaction Reports (CTR) ,
Filing Deadlines ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
New Guidance ,
Regulatory Oversight ,
Regulatory Requirements ,
Reporting Requirements ,
Suspicious Activity Reports (SARs)
A federal appeals court ruled on August 29, 2025, that most of the Trump Administration’s sweeping tariffs on imports from U.S. trading partners, including reciprocal tariffs and anti-narcotics tariffs, are unlawful. The...more
On August 18, the U.S. Department of the Treasury issued a Request for Comment (RFC) in a direct step toward implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) and in support...more
8/25/2025
/ AML/CFT ,
Anti-Money Laundering ,
Artificial Intelligence ,
Blockchain ,
Comment Period ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Executive Orders ,
Secretary of the Treasury ,
Stablecoins ,
The GENIUS Act ,
U.S. Treasury
On August 5, the FDIC announced that banks it supervises can comply with Bank Secrecy Act (BSA) requirements to obtain identity information from new customers by using a pre-populated form, provided that the person opening...more
The President’s Working Group on Digital Asset Markets on July 30 released Strengthening American Leadership in Digital Financial Technology. This report, issued under January's Executive Order 14178, outlines a sweeping set...more
The U.S. government is scheduled to begin collecting considerably higher tariffs on most imports on August 7. Companies need to adapt their compliance arrangements to a new, high-tariff environment. An appendix to this alert...more
On July 21, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) announced that it was postponing and reevaluating the anti-money laundering (AML) rule for investment advisers (Adviser AML...more
President Trump has ended the broad U.S. sanctions embargo on Syria, but sanctions against certain designated targets remain in place. As of July 1, 2025, Executive Order 14312: Rescinds the Treasury Department’s Office of...more
The Department of Justice’s (DOJ) 90-day grace period for compliance with the Data Security Program (DSP) ends on July 8, 2025, and enforcement is expected to begin. This regulatory regime was created for national security...more
7/7/2025
/ China ,
Corporate Counsel ,
Covered Person ,
Cross-Border Transactions ,
Data Privacy ,
Data Security ,
Department of Justice (DOJ) ,
Enforcement Actions ,
International Data Transfers ,
National Security ,
Regulatory Requirements
On April 11, 2025, the Department of Justice’s (DOJ) National Security Division (NSD) released an Implementation and Enforcement Policy, a Compliance Guide, and a list of over 100 Frequently Asked Questions (FAQs) to help...more
On March 21, 2025, the Financial Crimes Enforcement Network of the U.S. Treasury Department (“FinCEN”) narrowed the scope of the beneficial ownership information (“BOI”) filing requirement under the Corporate Transparency Act...more
FinCEN announced that by March 21, 2025, it plans to issue an interim final rule that will extend the current beneficial ownership information (BOI) reporting deadlines under the Corporate Transparency Act. Until the new rule...more
The Corporate Transparency Act (CTA) is back in effect − at least for now − and companies covered by the CTA are once again required to file beneficial ownership information (BOI) reports with FinCEN. On February 17, 2025, in...more
On January 23, 2025, the U.S. Supreme Court vacated one nationwide stay (Texas Top Cop Shop, Inc. v. McHenry – formerly, Texas Top Cop Shop v. Garland) which blocked the U.S. government from enforcing the Corporate...more
The Department of Justice has finalized prohibitions and restrictions on cross-border transfers of certain data to China and other “Countries of Concern” (as defined below). It seeks to address what is, in the U.S....more
1/21/2025
/ Artificial Intelligence ,
China ,
Cuba ,
Data Privacy ,
Data Security ,
Department of Justice (DOJ) ,
International Data Transfers ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
National Security ,
Personal Data ,
Russia
The Department of Justice (DOJ) has proposed a significant restriction on cross-border transfers of sensitive personal data to designated “countries of concern.” The goal is to address national security risks posed by...more
12/13/2024
/ Biometric Information ,
CFIUS ,
Cybersecurity Information Sharing Act (CISA) ,
Data Protection ,
Department of Justice (DOJ) ,
International Data Transfers ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Personal Data ,
Popular ,
Proposed Rules
A federal judge has blocked the U.S. government from enforcing the Corporate Transparency Act (CTA) and its implementing regulations nationwide. As a result, companies affected by the CTA do not have to report information...more
Financial institutions face significant new compliance obligations under export control guidance issued by the Commerce Department’s Bureau of Industry and Security (BIS) last month. ...more
The deadline is quickly approaching for companies created or registered to do business in the United States before 2024 to report beneficial ownership information as required by the Corporate Transparency Act (CTA). The CTA...more
On September 6, 2024, the Bureau of Industry and Security (BIS) of the U.S. Commerce Department issued an interim final rule expanding export controls on certain emerging technologies: Quantum Computing: Quantum computers,...more
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a rule to counter money laundering and the financing of terrorism that would add significant compliance requirements for financial...more
The United States has substantially expanded economic sanctions and export controls targeting Russia and Belarus, imposing new restrictions that could have a major impact on companies with business activities in or relating...more
The 21st Century Peace Through Strength Act became law recently as part of H.R. 815, which also provided aid to Ukraine, Israel and Taiwan. The law contains important sanctions measures that: Extend the statute of...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced two enforcement actions this year. Both reference the Financial Crimes Enforcement Network's (FinCEN) whistleblower program,...more