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)
The U.S. Commerce Department has expanded export control sanctions by extending them to 50% or more-owned affiliates of restricted parties. This development has a particularly significant impact on China-related export...more
10/3/2025
/ Affiliates ,
Bureau of Industry and Security (BIS) ,
China ,
Cooperative Compliance Regime ,
Economic Sanctions ,
Export Controls ,
Foreign Direct Product Rule ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Supply Chain ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies
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 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
Orrick Partners Matthew Coleman and Jeanine McGuinness join RegFi co-hosts Jerry Buckley and Sherry Safchuk to explore the implications of the Justice Department’s recent issuance of a final rule prohibiting and restricting...more
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
Q1 2025 marked another strong quarter for life sciences VC financing, but the industry faces unique headwinds amid ongoing shake-ups in regulatory leadership and US trade relationships. Key takeaways for Q1 2025 include: •...more
An update to our ongoing insights into the Trump administration’s broad tariffs on imports from Canada, Mexico and China. On April 2, 2025, President Trump unveiled a new so-called “reciprocal” tariff regime. The...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
On February 21, 2025, a Presidential Memorandum, “America First Investment Policy” (the “Memorandum”), announced planned changes to the Committee on Foreign Investment in the United States (“CFIUS”) and outbound investment...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
The United States has announced, subject to reported suspensions with the two countries, 25% duties on most imports from Canada and Mexico, as well as 10% duties on most imports from China. These duties build on existing...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
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
On October 28, 2024, the U.S. Department of the Treasury issued its final outbound investment rule, which implements Executive Order 14105, prohibiting certain outbound investments by U.S. persons in Chinese and China-related...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