On May 12, 2025, Matthew R. Galeotti, the head of the DOJ’s Criminal Division, gave a speech at SIFMA’s Money Laundering and Financial Crimes Conference that previewed subsequently issued policy changes impacting the Criminal...more
5/16/2025
/ Anti-Money Laundering ,
Corporate Culture ,
Corporate Governance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Policies and Procedures ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
On March 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published the text of an interim rule formally revising the Corporate Transparency Act’s (CTA) definition of “reporting...more
Last week, we reported that the Financial Crimes Enforcement Network (FinCEN) reinstated the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements, with a new deadline for most...more
3/3/2025
/ Beneficial Owner ,
Compliance ,
Corporate Transparency Act ,
Enforcement Actions ,
Filing Deadlines ,
FinCEN ,
New Legislation ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Temporary Hold
Earlier this week, the Financial Crimes Enforcement Network (FinCEN) issued a new notice confirming that the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements are back in effect....more
The Foreign Corrupt Practices Act (FCPA), passed in the wake of Watergate, prohibits U.S.-linked companies and individuals from bribing foreign government officials to procure international business and hiding the bribes in...more
President Donald Trump has issued a presidential memorandum, which has the effect of an Executive Order, titled “Regulatory Freeze Pending Review“ (the Regulatory Freeze). This Regulatory Freeze puts a hold on new agency...more
As of January 23, 2025, the regulation discussed below has not been withdrawn by the Trump administration and is not subject to automatic withdrawal under President Trump’s Executive Order freezing regulations. It currently...more
1/24/2025
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Biden Administration ,
Compliance ,
Data Protection ,
Data Security ,
Department of Justice (DOJ) ,
Executive Orders ,
Final Rules ,
National Security ,
NPRM ,
Pending Legislation ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management ,
Trump Administration
President-elect Donald Trump’s second term will almost certainly usher in profound changes to U.S. international trade and national security policy....more
1/17/2025
/ China ,
Donald Trump ,
Free Trade Agreements ,
International Trade ,
National Security ,
Section 232 ,
Section 301 ,
Tariffs ,
Trade Policy ,
Trade Relations ,
USTR
On January 2, 2025, the U.S. Department of the Treasury’s (Treasury) regulation restricting U.S. outbound investments in certain advanced technology sectors in China (the Final Rule) takes effect. Thereafter, investments by...more
12/31/2024
/ Artificial Intelligence ,
CFIUS ,
Covered Transactions ,
Final Rules ,
Foreign Investment ,
Foreign Persons ,
Lawful Permanent Residents ,
National Security ,
Outbound Transactions ,
Private Equity ,
Prohibited Transactions ,
Technology ,
U.S. Treasury
As reported in our recent Update, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the beneficial ownership information reporting requirements of the...more
12/31/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reinstatement ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays ,
Vacated
The U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the beneficial ownership information reporting requirements of the Corporate Transparency Act (CTA)...more
12/11/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Counsel ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
Final Rules ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays
The Corporate Transparence Act was a part of landmark anti-money laundering legislation passed in 2021. It was designed to shift reporting of corporate ownership from a hodgepodge of different financial institutions to the...more
The U.S. Department of Justice (DOJ) announced criminal charges in five cases in connection with the Disruptive Technology Strike Force (Strike Force) on September 16, 2024. Launched in February 2023, the Strike Force is...more
June marked the six-month milestone for the implementation of the Corporate Transparency Act (CTA)—the landmark anti-money laundering law requiring beneficial ownership reporting for U.S. companies that became effective on...more
8/5/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Counsel ,
Corporate Transparency Act ,
Enforcement ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Noncompliance ,
Penalties ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
On March 1, 2024, New York Governor Kathy Hochul signed an amended version of the New York LLC Transparency Act (NYLTA), which was originally signed with provisions for amendments in December 2023. The NYLTA will go into...more
The CTA and Legal Challenges -
The CTA is a sweeping new anti-money-laundering law that, as of January 1, 2024, requires most entities formed or registered to do business in the United States to disclose detailed...more
As discussed in our prior Update on the Corporate Transparency Act (CTA), anyone who owns or controls at least 25% of the ownership interests of a CTA reporting company must report their beneficial ownership to the Financial...more
The Corporate Transparency Act (CTA), designed to combat the use of shell companies for illicit purposes and increase ownership transparency in corporate structures, takes effect on January 1, 2024. As discussed in more...more
The Corporate Transparency Act (CTA) became law on January 1, 2021, and requires companies formed and/or operating in the United States to disclose beneficial ownership information through a database that will be maintained...more
Key portions of the Corporate Transparency Act (CTA) will take effect on January 1, 2024, requiring an estimated 30 million “reporting companies” to disclose to the federal government information and documentation about the...more
12/11/2023
/ Beneficial Owner ,
Business Entities ,
Corporate Governance ,
Corporate Transparency Act ,
Doing Business ,
Filing Deadlines ,
Financial Regulatory Reform ,
FinCEN ,
Publicly-Traded Companies ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
Beginning January 1, 2024, the Corporate Transparency Act (CTA) will require most entities formed or registered to do business in the United States to disclose detailed information regarding their owners, officers, and...more
12/5/2023
/ AML/CFT ,
Anti-Money Laundering ,
Beneficial Owner ,
Business Ownership ,
Civil Monetary Penalty ,
Compliance ,
Corporate Governance ,
Corporate Transparency Act ,
Exemptions ,
Financial Crimes ,
Financial Regulatory Reform ,
FinCEN ,
Recordkeeping Requirements ,
Regulatory Requirements ,
Reporting Requirements
The Federal Financial Institutions Examination Council (FFIEC) released the fifth phase of updates to the FFIEC Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual (the Manual) on August 2, 2023. While the...more
President Biden issued a long-awaited executive order, “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern” (the Executive Order or E.O.), on August 9, 2023,...more
8/17/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Biden Administration ,
China ,
Compliance ,
Corporate Governance ,
Covered Person ,
Exceptions ,
Executive Orders ,
Foreign Direct Investment ,
Investment ,
Investors ,
National Security ,
Popular ,
Technology Sector ,
U.S. Treasury ,
White Collar Crimes
Regulated gaming is booming in the United States. This is particularly true of newer forms of gambling, such as skill games, fantasy sports, and social casino games played on the internet and mobile applications. In fact,...more
7/12/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Emerging Technology Companies ,
Enforcement ,
Fantasy Sports ,
Financial Institutions ,
FinCEN ,
Gambling ,
Gambling Acts ,
Gaming ,
Investigations ,
Online Gaming ,
Regulatory Requirements ,
Sports Gambling ,
State and Local Government ,
UK ,
Venture Capital ,
Video Games ,
White Collar Crimes
The U.S. Department of Justice (DOJ) on March 3, 2023, unveiled a new pilot program and announced several important updates to its Evaluation of Corporate Compliance Programs (ECCP) regarding corporate compensation incentives...more
3/21/2023
/ Clawbacks ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Compensation ,
Guidance Update ,
Incentives ,
Pilot Programs ,
White Collar Crimes