Industry-Specific Primer – Semiconductor Manufacturing And Advanced Packaging -
On June 8, 2021, the Biden Administration issued the reports mandated by the Executive Order on America’s Supply Chains (the “America’s Supply...more
6/14/2021
/ Biden Administration ,
Buy American Act ,
CFIUS ,
Coronavirus/COVID-19 ,
Defense Production Act ,
Department of Defense (DOD) ,
Executive Orders ,
Export Controls ,
Export-Import Bank of the US ,
Federal Acquisition Regulations (FAR) ,
National Security ,
NDAA ,
NIST ,
Popular ,
Research and Development ,
Semiconductors ,
Supply Chain ,
Supply Shortages ,
Trade Expansion Act of 1962 ,
U.S. Commerce Department
On June 8-9, 2021, the World Trade Organization’s (WTO) TRIPS Council will hold their first meeting in the wake of the U.S. Trade Representative (USTR) announcing “the Biden-Harris Administration’s support for waiving...more
6/8/2021
/ Bilateral Investment Treaties ,
Copyright ,
Coronavirus/COVID-19 ,
Industrial Design ,
Intellectual Property Protection ,
Pharmaceutical Industry ,
Pharmaceutical Patents ,
Popular ,
Takings Clause ,
Trade Secrets ,
TRIPS Agreement ,
Tucker Act ,
United States-Mexico-Canada Agreement (USMCA) ,
USTR ,
Vaccinations ,
Waivers ,
WTO
Modernizing FinCEN’s Whistleblower Program Under the Anti-Money Laundering Act of 2020 -
INTRODUCTION -
Reporting on multiple international money-laundering schemes last year brought public focus to the anti-money...more
5/21/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
CFTC ,
Department of Justice (DOJ) ,
Dodd-Frank ,
False Claims Act (FCA) ,
FinCEN ,
IRS ,
NDAA ,
Sarbanes-Oxley ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers
On March 19, 2021, the Financial Action Task Force (“FATF”), an intergovernmental body tasked with setting international standards aimed at preventing money laundering and terrorist financing (“FATF Standards”), released its...more
4/12/2021
/ Anti-Money Laundering ,
Cross-Border Transactions ,
Cryptocurrency ,
Digital Assets ,
FATF ,
Guidance Update ,
Information Sharing ,
Licensing Rules ,
Peer-to-Peer ,
Registration Requirement ,
Risk Mitigation ,
Terrorist Financing ,
Transfer of Assets ,
Travel Rule
Companies holding intellectual property in medical products used in the fight against COVID-19 should be aware of formal efforts by a group of nearly 60 developing countries, led by India and South Africa, to obtain a waiver...more
3/5/2021
/ Bilateral Investment Treaties ,
Coronavirus/COVID-19 ,
Diagnostic Tests ,
Foreign Investment ,
Free Trade Agreements ,
Intellectual Property Protection ,
Medical Devices ,
Personal Protective Equipment ,
Prescription Drugs ,
TRIPS Agreement ,
Vaccinations ,
Waivers ,
WTO
Articulates Administration Policy And Reaffirms Need For “Strong, Resilient Supply Chains” For “Critical And Essential Goods And Materials” -
On February 24, 2021, President Joseph R. Biden Jr. signed an Executive Order on...more
2/26/2021
/ Batteries ,
Biden Administration ,
Energy Sector ,
Executive Orders ,
Food Supply ,
Goods or Services ,
Information and Communication Technology (ICT) ,
Manufacturers ,
Minerals ,
National Security ,
Popular ,
Prescription Drugs ,
Risk Management ,
Supply Chain ,
Telecommunications ,
Transportation Industry
As we wrote over the summer, Congress has passed a bill that will require certain corporations and limited liability companies (“LLCs”) to report information on their beneficial owners to the U.S. Treasury Department’s...more
12/23/2020
/ Anti-Money Laundering ,
Civil Monetary Penalty ,
Currency Transaction Reports (CTR) ,
Customer Due Diligence (CDD) ,
Department of Justice (DOJ) ,
FinCEN ,
Internal Revenue Code (IRC) ,
Limited Liability Company (LLC) ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Securities Exchange Act ,
Shell Corporations ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury ,
Whistleblowers
In October of last year, we wrote about the challenges faced by virtual currency businesses in complying with the Travel Rule following new guidance from the Financial Action Task Force (FATF) and the Financial Crimes...more
11/5/2020
/ Bank Secrecy Act ,
Compliance ,
Cryptocurrency ,
Department of Justice (DOJ) ,
FATF ,
Federal Reserve ,
Financial Institutions ,
FinCEN ,
Proposed Rules ,
Suspicious Activity Reports (SARs) ,
Travel Rule ,
Uniform Commercial Code (UCC) ,
Virtual Currency ,
Wire Transfers
Bank Secrecy Act Update: The Financial Crimes Enforcement Network Details Its Bank Secrecy Act Enforcement Approach; Bank Regulators Provide Guidance on Their Approach to BSA Enforcement; FinCEN’s Final Rule Requiring BSA...more
9/22/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Cease and Desist Orders ,
FDIA ,
Federal Credit Unions ,
Final Rules ,
FinCEN ,
New Guidance ,
Notice of Proposed Rulemaking (NOPR) ,
U.S. Treasury
If the U.S. House of Representatives has its way, some corporations will soon be required to report information on their beneficial owners to the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”). On...more
On March 4, 2020, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced its assessment of a civil monetary penalty totaling $450,000 against Michael LaFontaine, a former Chief Operational...more
The Financial Action Task Force (“FATF”) held its 31st plenary meeting during February 19-21, 2020. Among other things, the FATF classified Iran as a “high-risk jurisdiction” and called for certain countermeasures to be...more
3/4/2020
/ AML/CFT ,
Blocking Statutes ,
EU ,
FATF ,
Financial Action Task Force ,
FinCEN ,
High-Risk Countries ,
Iran ,
Money Laundering ,
New Regulations ,
Terrorist Financing Regulations
The Office of the U.S. Trade Representative (“USTR”) is seeking comments on whether to extend product exclusions from section 301 tariffs imposed on certain imports from China. Effective July 6, 2018, USTR imposed additional...more
On Monday December 2, 2019, the Office of the United States Trade Representative (“USTR”) posted a notice announcing that it was proposing tariffs of up to 100 percent on 63 types of goods imported from France worth...more
The Office of the U.S. Trade Representative (“USTR”) has announced an exclusion process for the additional duties imposed September 1, 2019 on a list of products (“List 4A”) pursuant to the U.S. Section 301 action against...more
The Travel Rule is an old friend for those familiar with banking regulations and anti-money laundering rules. The Rule, first issued by FinCEN in 1995 with fiat currency in mind, requires banks and nonbank financial...more
10/2/2019
/ Anti-Money Laundering ,
Bitcoin ,
Cryptocurrency ,
Data Security ,
FATF ,
FinCEN ,
Money Services Business ,
New Guidance ,
Public Comment ,
Regulatory Requirements ,
Travel Rule ,
Virtual Currency
Tariffs To Be Effective On September 1, 2019 For Some Products And December 15, 2019 For Others; Certain Products Will Not Be Subject To Additional Tariffs; Product Exclusion Process To Be Implemented.
...more
On June 20, 2019, the Office of the U.S. Trade Representative (“USTR”) posted on its website a notice announcing an exclusion process for the tariffs imposed in September 2018 (“List 3”) pursuant to the U.S. Section 301...more
6/24/2019
/ China ,
Exclusions ,
Imports ,
Notice Requirements ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trade Relations ,
Trump Administration ,
US Trade Policies ,
USTR
For the past several years, advocates of crypto assets and other public uses of blockchain technology have sought guidance from U.S. regulators regarding the legal implications of new or novel uses of that technology....more
5/21/2019
/ Anonymization ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Blockchain ,
BSA/AML ,
CFTC ,
Cryptocurrency ,
Digital Wallets ,
FinCEN ,
Initial Coin Offering (ICOs) ,
Money Services Business ,
New Guidance ,
Peer-to-Peer ,
Securities and Exchange Commission (SEC) ,
Virtual Currency
USTR on May 13, 2019 announced that it proposed to impose additional tariffs on products of China with an annual trade of approximately $300 billion pursuant to a Section 301 investigation commenced in August 2017 regarding...more
Although U.S.-China trade negotiations had appeared in recent weeks to be moving toward an agreement, the President tweeted on May 5 that the 10 percent tariff currently imposed on $200 billion in Chinese imports will...more
New Executive Order Would Expand Domestic Preferences In Federal Procurement For Infrastructure Projects -
On January 31, 2019, President Trump signed an Executive Order (“EO”) entitled “Strengthening Buy-American...more
While many of us were winding down the year focused on the December holidays, the U.S. Department of Justice, the SEC, FINRA, and FinCEN were busy delivering a flurry of messages to the broker-dealer industry about AML...more
Tariffs on $200 billion in Chinese imports were set to rise to 25% on January 1, 2019, but will remain at 10% for 90 days pending negotiations with China on “structural changes” to U.S.-China economic relationship -
On...more
In July and August, 2018 the United States Trade Representative (USTR) identified a list of 6,031 tariff lines affecting approximately $200 billion in imports from China for potential additional tariffs of 10 percent and...more