On March 21, 2025 FinCEN published an interim final rule that eliminates “beneficial ownership information” (BOI) reporting requirements for all domestic companies. ...more
In the ongoing saga of the Corporate Transparency Act (CTA) and its Beneficial Ownership Interest (BOI) reporting requirements, FinCEN has yet again paused enforcement. On February 27, FinCEN announced that it will not impose...more
The Corporate Transparency Act (CTA) and its beneficial ownership information (BOI) reporting requirements are back in effect. On Monday, February 18, 2025, a federal district court in Texas granted a stay of the nationwide...more
2/20/2025
/ Beneficial Owner ,
Corporate Transparency Act ,
Enforcement Actions ,
Filing Deadlines ,
FinCEN ,
Garland v Texas Top Cop Shop ,
Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays ,
U.S. Treasury
On January 23, 2025, it appeared that the Supreme Court had given the green light to FinCEN to resume enforcement of the Corporate Transparency Act (CTA) and its beneficial ownership information reporting requirements after...more
The Fifth Circuit Court of Appeals has reinstated the stay with respect to Corporate Transparency Act (CTA) compliance which means that the Financial Crimes Enforcement Network of the U.S. Department of Treasury (FinCEN) is...more
12/30/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Corruption ,
Financial Crimes ,
FinCEN ,
National Security ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit granted a stay of the previously issued nationwide injunction in Texas Top Cop Shop, Inc., et al. v. Garland, et al., which had the effect of reinstating...more
12/27/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Corruption ,
Filing Deadlines ,
Financial Crimes ,
FinCEN ,
National Security ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays ,
Time Extensions
In our recent update on the nationwide preliminary injunction issued against the Corporate Transparency Act (CTA) and its beneficial ownership information (BOI) reporting requirements, we noted that we would continue to...more
12/18/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Appeals ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Corruption ,
Financial Crimes ,
FinCEN ,
National Security ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements
On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction in Texas Top Cop Shop, Inc., et al. v. Garland, et al., temporarily halting the enforcement of the...more
12/10/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Corruption ,
Financial Crimes ,
FinCEN ,
National Security ,
Popular ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements
The Corporate Transparency Act (CTA), the federal initiative to limit money laundering, tax evasion, and other illicit activities, took effect on Jan. 1, 2024. The CTA requires many businesses and their owners to register...more
11/13/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Cooperative Compliance Regime ,
Corporate Transparency Act ,
Filing Deadlines ,
Financial Crimes ,
FinCEN ,
National Security ,
Ownership Interest ,
Popular ,
Regulatory Requirements ,
Reporting Requirements
Several new laws and amendments went into effect last week on, July 1, 2024, bringing major changes to the cannabis and hemp industry in Connecticut. Here's a detailed look at the primary bill, Public Act 24-76 (the “Act”),...more
**Updated November 30, 2023**
On January 1, 2024, the new federal Corporate Transparency Act (CTA) will take effect. The CTA is a new federal initiative to limit money laundering that will require most companies and their...more
On August 28, 2023 the Social Equity Council (SEC) and Connecticut’s Department of Economic and Community Development (DECD) announced the launch of the much anticipated Canna-Business Revolving Loan Fund that will provide...more
8/30/2023
/ Agribusiness ,
Cannabis Products ,
Cannabis-Related Businesses (CRBs) ,
Commercial Loans ,
Connecticut ,
Decriminalization of Marijuana ,
Dispensaries ,
Equal Access to Credit ,
Financial Services Industry ,
Licenses ,
Marijuana ,
Marijuana Cultivation ,
Marijuana Related Businesses ,
State and Local Government
Connecticut’s health information exchange (HIE), Connie, is live and operational. Pursuant to Connecticut Public Act 17-2, hospitals and labs only have until May 3, 2022 to begin the process of connecting with Connie. All...more
Recently, the Office of the National Coordinator for Health IT (ONC) issued a new series of helpful FAQs related to its information blocking regulations. The new FAQs cover a wide range of topics, including the content and...more
12/9/2021
/ Data Protection ,
Department of Health and Human Services (HHS) ,
Document Requests ,
Electronic Medical Records ,
Electronic Protected Health Information (ePHI) ,
Health Care Providers ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Healthcare ,
Information Blocking Rules ,
Information Technology ,
ONC ,
Regulatory Agenda ,
Regulatory Requirements
Welcome to Manufacturing Updates, Pullman & Comley’s quarterly publication that summarizes important legal developments for manufacturers. Manufacturing Updates brings together insights from attorneys across our many practice...more
9/28/2021
/ Consumer Financial Products ,
Coronavirus/COVID-19 ,
Data Privacy ,
Employer Mandates ,
Financial Services Industry ,
Infectious Diseases ,
Libor ,
Loans ,
Manufacturers ,
Manufacturing Facilities ,
Property Tax ,
Secured Overnight Funding Rate (SOFR) ,
Tax Planning ,
Vaccinations ,
Workplace Safety
For many manufacturers, data privacy and protection laws may seem like legal concerns that apply to other, more consumer-facing companies. While that may be largely true, given the ubiquitous nature of data, no business can...more
In 2018, we published an article on Walgreens’ use of session replay scripts and how such use could lead to an accidental data breach under HIPAA. Last week, an article in Vox explained how Walgreens was again apparently...more
Monday, April 5th, marked the deadline for compliance with the information blocking regulations implemented by the Office of the National Coordinator for Health IT (ONC). As a follow-up to our earlier FAQs on these new...more
4/9/2021
/ 21st Century Cures Act ,
Data Privacy ,
Data Protection ,
Electronic Medical Records ,
Electronic Protected Health Information (ePHI) ,
Health Care Providers ,
Health Information Technologies ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Information Blocking Rules ,
Information Technology ,
ONC ,
Patient Privacy Rights ,
Regulatory Requirements
Spring is approaching, pandemic restrictions are (we hope responsibly) lifting, and the April 5, 2021 deadline for compliance with the new information blocking rules are looming. We continue our Frequently Asked Question...more
Navigating the challenges posed by the new information blocking rules issued by the Office of the National Coordinator for Health IT (ONC) is not solely the job of IT Departments, outside consultants and software companies. ...more
One of the many changes brought by the COVID-19 pandemic may be the permanent expansion of telehealth. According to a recent study, the US telehealth market is expected to witness 80% year-over-year growth in 2020. ...more
Connecticut healthcare providers should give heed to three sets of recently proposed rules issued by the U.S. Department of Health & Human Services (HHS) interpreting some of the federal laws relating to electronic health...more
According to a recent U.S. Government Interagency report, ransomware is the fastest growing malware threat, targeting users of all types. An incredible 51 percent of respondents in a January 2017 study by the Ponemon...more
10/30/2017
/ Cyber Attacks ,
Cyber Crimes ,
Cybersecurity ,
Data Breach ,
Electronic Medical Records ,
Hackers ,
Health Care Providers ,
Health Insurance Portability and Accountability Act (HIPAA) ,
HIPAA Breach ,
Information Technology ,
Malware ,
OCR ,
Personally Identifiable Information ,
PHI ,
Popular ,
Ransomware ,
Risk Management ,
Security Rule ,
State Data Breach Notification Statutes
As its next step in the creation and implementation of a cybersecurity plan, the State of Connecticut has created a Cybersecurity Strategy document. This strategy specifically highlights the roles and vulnerabilities of state...more
According to a recent US Government Interagency report, ransomware is the fastest growing malware threat, targeting users of all types, including health care facilities. This past spring, for example, the WannaCry ransomware...more
7/11/2017
/ Cyber Attacks ,
Cybersecurity ,
Data Breach ,
Hackers ,
Health Care Providers ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Malware ,
OCR ,
PHI ,
Popular ,
Ransomware