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Mayer Brown

In Brief: FinCEN Confirms Suspension of Corporate Transparency Act Filing Obligations During Nationwide Injunction

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On December 7, 2024, the US Financial Crimes Enforcement Network (FinCEN) confirmed that reporting companies—i.e., companies that would be required to report their beneficial ownership information to FinCEN under the...more

Stinson LLP

Trump's First 100 Days: Banking & Financial Services

Stinson LLP on

While existing regulations won't be erased overnight, the Trump Administration can quickly rescind informal agency guidance, including advisory opinions, interpretive rules and policy statements, creating opportunities for...more

Bilzin Sumberg

New Florida Condo Rules: Developer Buyouts Offer Lifelines to Owners

Bilzin Sumberg on

The deadline for associations to receive their completed structural reserve studies is Dec. 31. Across the state, condo owners and their associations are going to soon be waking up to the reality that their financial...more

Coblentz Patch Duffy & Bass

Corporate Transparency Act Blocked Nationwide by Texas Court

On Tuesday, December 3, 2024, a Texas federal judge granted a preliminary injunction halting the continuing implementation of the Corporate Transparency Act (CTA) and its beneficial ownership information (BOI) reporting...more

The Volkov Law Group

BIT Mining Bribery Scheme — CEO Directed Payments and the Cover-Up (Part II of III)

The Volkov Law Group on

In reviewing FCPA bribery fact patterns, it is a rare occasion when a company’s CEO is at the epicenter of the criminal conspiracy. In the BIT Mining case, standing atop all of the actors is the CEO Zhengming Pan, Bit...more

Seyfarth Shaw LLP

FinCEN Acknowledges Nationwide Preliminary Injunction on CTA Enforcement – Voluntary Submission Only

Seyfarth Shaw LLP on

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., blocking enforcement of the Corporate...more

Troutman Pepper

FTC Distributes $540,000 in Refunds to Victims of Deceptive Debt Collection Scheme

Troutman Pepper on

On December 10, the Federal Trade Commission (FTC) announced that it is distributing more than $540,000 in refunds to victims of an abusive debt collector group. The debt collectors allegedly threatened consumers with...more

Ballard Spahr LLP

HUD extends compliance date for portions of “Modernization of Engagement with Mortgagors in Default’’ rule

Ballard Spahr LLP on

The U.S. Department of Housing and Urban Development (HUD) has extended from January 1, 2025 until July 1, 2025, the compliance date for certain provisions of the department’s rule entitled “Modernization of Engagement with...more

Skadden, Arps, Slate, Meagher & Flom LLP

Fintech Focus Podcast | Navigating IT and Security Risks in Fintechs in Light of Impending DORA Deadline

As we approach the end of the year, so too do fintechs approach the impending deadline for implementing the raft of requirements under the EU’s Digital Operational Resilience Act (DORA). Cybersecurity and data privacy counsel...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - December 2024 # 2

Troutman Pepper on

To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Patterson Belknap Webb & Tyler LLP

Takeaways from the SEC Division of Enforcement’s FY 2024 Report

On November 22, 2024, the Securities and Exchange Commission (the “SEC”) published its enforcement results for fiscal year of 2024. The report shows a mixed result. The SEC only brought 583 actions in FY 2024, a 26% decrease...more

A&O Shearman

UK Financial Conduct Authority Policy Statement on Changes to Financial Crime Guide

A&O Shearman on

The U.K. Financial Conduct Authority has published a policy statement on changes to its financial crime guide, following its consultation in April. The changes cover the following areas: (i) sanctions—to reflect information...more

Jenner & Block

Client Alert: Mr. Bitcoin Goes to Washington

Jenner & Block on

Few industries experienced a more drastic reversal of fortune on Election Day than the cryptocurrency sector. On November 4, several of its largest companies were locked in a seemingly interminable battle with the Securities...more

A&O Shearman

Implementing Regulation on Standard Templates for the Register of Information

A&O Shearman on

The European Commission rejected the European Supervisory Authorities' draft ITS in September on the basis that financial entities should have the choice of using either EU unique identifiers or legal entity identifiers. The...more

A&O Shearman

Fifth Circuit Limits OFAC Authority Over Certain Cryptocurrency Products

A&O Shearman on

On November 26, 2024, the Fifth Circuit Court of Appeals held that the United States Office of Foreign Assets Control (“OFAC”) exceeded its authority by adding an entity that pools and anonymizes crypto transactions to OFAC’s...more

A&O Shearman

DC Circuit Grants Preliminary Injunction Preventing FINRA From Expelling Member Without SEC Review, Finding Private Nondelegation...

A&O Shearman on

On November 22, 2024, the D.C. Circuit Court of Appeals enjoined the Financial Institution Regulatory Authority (“FINRA”) from expelling a member firm without Securities and Exchange Commission (“SEC”) review. Alpine...more

Ballard Spahr LLP

CFPB Proposes Broad New Data Broker Rule That Would Greatly Expand the FCRA

Ballard Spahr LLP on

On December 3, 2024, the Consumer Financial Protection Bureau (CFPB) published its long anticipated proposed rule aimed at regulating data brokers under the Fair Credit Reporting Act (FCRA).  Although the CFPB’s future is...more

A&O Shearman

Bank of England Consults on Revocation of UK Technical Standards on Simplified Obligations

A&O Shearman on

The Bank of England has published a consultation paper on the proposed revocation of the U.K. technical standards on simplified obligations. The U.K. retained the EU framework for determining the level of information required...more

Faegre Drinker Biddle & Reath LLP

SEC 2025 Examination Priorities: Retirees and Rollovers

The SEC’s Division of Examinations issued its 2025 Exam Priorities a few months ago. 2025-exam-priorities.pdf Many articles have been written about those priorities, but none—at least that I have seen—have addressed the focus...more

Skadden, Arps, Slate, Meagher & Flom LLP

A Review of the UK and EU Approaches to Third Country Branches and Subsidiarisation

Financial centres around the world have been hosts to branches and representative offices of international banks since as early as the 19th century. The term “branch” refers to a local establishment of a foreign financial...more

A&O Shearman

International Organization of Securities Commissions Publishes Final Report on Evolution of Market Structures

A&O Shearman on

The International Organization of Securities Commissions has published its final report on the evolution in the operation, governance, and business models of exchanges. The Report focuses on equity exchanges, but IOSCO...more

Akin Gump Strauss Hauer & Feld LLP

CFTC’S Year-End AI “Placeholder” Guidance

On December 5, 2024, the Staff of every market-facing division of the U.S. Commodity Futures Trading Commission (CFTC) issued a joint “Staff Advisory” on the use of artificial intelligence in CFTC-regulated markets and...more

A&O Shearman

New UK Financial Conduct Authority Direction for the Derivatives Trading Obligation

A&O Shearman on

The U.K. Financial Conduct Authority has published a new direction for the U.K. derivatives trading obligation, together with an explanatory memorandum. The FCA's existing direction modifying the U.K. DTO using its Temporary...more

A&O Shearman

Transparency on Hold: FinCEN confirms a halt to Corporate Transparency Act reporting (for now)

A&O Shearman on

For the past week, millions of companies have been eagerly awaiting the Financial Crimes Enforcement Network’s (FinCEN) statement in response to the December 3, 2024 preliminary injunction that has halted enforcement of the...more

Woods Rogers

Corporate Transparency Act Enjoined: How should your company respond now?

Woods Rogers on

The reporting requirement of the Corporate Transparency Act (CTA) was preliminarily enjoined on December 3, 2024, by an Order of the U.S. District Court for the Eastern District of Texas. The Court issued a nationwide...more

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