On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced a suspension of enforcement actions related to the Corporate Transparency Act (“CTA”). This announcement means that reporting companies are...more
3/7/2025
/ Beneficial Owner ,
Compliance ,
Corporate Counsel ,
Corporate Transparency Act ,
Enforcement Actions ,
Filing Deadlines ,
FinCEN ,
Proposed Rules ,
Regulatory Requirements ,
Reporting Requirements ,
U.S. Treasury
Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt...more
On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction that was issued by a Texas federal judge in the case Texas Top Cop Shop, Inc. v. McHenry. As we discussed previously,...more
1/29/2025
/ Anti-Money Laundering ,
Appeals ,
Beneficial Owner ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Crimes ,
FinCEN ,
Injunctions ,
Reporting Requirements ,
SCOTUS
As Donald J. Trump prepares to begin his second presidential administration on January 20, 2025, many Department of Justice (“DOJ”) priorities and policies are likely to change. One new Biden administration initiative that is...more
1/13/2025
/ Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
As we approach Inauguration Day on January 20, 2025, one question among anticorruption practitioners is how the Trump administration will handle enforcement of the Foreign Corrupt Practices Act (“FCPA”). In the meantime, we...more
12/23/2024
/ Anti-Corruption ,
Bribery ,
Corporate Crimes ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Popular ,
Securities and Exchange Commission (SEC) ,
Trump Administration
For more than a decade, the U.S. Securities and Exchange Commission (the “SEC”) has been able to bring enforcement actions in either federal court or the agency’s internal venue. Not anymore. On June 27, 2024, the U.S....more
7/1/2024
/ Administrative Law Judge (ALJ) ,
Administrative Proceedings ,
Article III ,
Civil Monetary Penalty ,
Enforcement Actions ,
Jury Trial ,
Public Rights Doctrine ,
SCOTUS ,
SEC v Jarkesy ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934 ,
Securities Fraud ,
Seventh Amendment
The U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) — the federal agency tasked with regulating the U.S. derivatives markets, which includes futures, swaps and certain kinds of options — has recently taken...more