Over the past few days, we here at MoFo’s National Security Practice Group have outlined the extraordinary pace of activity that the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) maintained in 2019 as...more
As we mentioned in the first part of our U.S. Sanctions Year in Review series, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) had an extraordinarily busy year in 2019, and its enforcement activity...more
On December 13, 2019, the Department of Justice’s National Security Division (“NSD”) announced a revised policy to encourage voluntary self-disclosures (“VSDs”) of criminal violations of export control and sanctions laws. The...more
On May 7, 2019, the Consumer Financial Protection Bureau (CFPB) issued proposed rules (“Proposed Rules”) under the Fair Debt Collection Practices Act (FDCPA) and its authority under the Dodd-Frank Act. If finalized, the...more
On March 21, 2018, a Consumer Financial Protection Bureau (CFPB or “Bureau”) Request for Information (RFI) on the CFPB’s adopted regulations and rulemaking authorities was published in the Federal Register. This RFI is the...more
On March 1, 2018, the Consumer Financial Protection Bureau (CFPB or “Bureau”) released its sixth Request for Information (RFI) as part of its initiative to reexamine the Bureau’s existing policies and procedures under Acting...more
On December 27, 2017, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) released its biennial report on the consumer credit card market (“2017 Report” or “Report”), which summarizes its views on the state of the...more
As we have noted previously, one of the defining aspects of the payments revolution of the past few years—at least from a regulatory perspective—has been the question of whether a particular payments service is subject to...more