A Look at Recent Federal Trade Commission and Consumer Financial Protection Bureau Initiatives Concerning Privacy and Data Security
2BInformed: Engaging with EPA, OSHA’s New Regulation, and Asbestos
Following consideration of comments received from an Advanced Notice of Proposed Rulemaking, on February 16, 2024, FinCEN issued a proposed rule (the “Proposed Rule”) that for the first time would require non-financed...more
The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more
On 9 August 2023, President Biden issued a long anticipated executive order imposing certain limitations, reporting requirements, and prohibitions on outbound investment from the United States into certain sensitive industry...more
In this issue, we discuss recent Delaware court decisions further developing the bounds around books and records demands. Other articles focus on recent developments concerning advance notice bylaws and the standards used by...more
On January 1, 2021, Congress passed the Corporate Transparency Act (“CTA” or the “Act”) to “better enable critical national security, intelligence and law enforcement efforts to counter money laundering, financing of...more
On December 8, 2021, the Federal Crimes Enforcement Network (“FinCEN”) division of the United States Treasury published an Advance Notice of Proposed Rulemaking (“ANPRM”) (Anti-Money Laundering Regulations for Real Estate...more
On December 7, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (NPRM or “Proposed Rule”) to implement the beneficial ownership information (BOI) reporting provisions of the...more
On December 7, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a highly anticipated proposed rule that would implement key provisions of the Corporate Transparency Act (CTA), a...more
Following its efforts in recent years to enforce the Foreign Agents Registration Act of 1938 (22 U.S.C. 611 et seq. (FARA)) more rigorously and transparently, for the first time in nearly 15 years, the U.S. Department of...more
The Financial Crimes Enforcement Network (FinCEN) of the Treasury Department announced last week a Notice of Proposed Rulemaking (NPRM) to implement the beneficial ownership reporting requirements set forth in the Corporate...more
In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more
The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) has issued a final rule that, for the first time ever, expands certain federal pipeline safety requirements to all onshore gas gathering pipelines,...more
As we reported in April, the Anti-Money Laundering Act of 2020 (AMLA 2020) aims to strengthen protections against money laundering, terrorism financing, and other illegal activities through a variety of mechanisms, including...more
On April 1, 2021, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) to solicit public comments on the implementation of the Corporate...more
The CTA is a recent reporting requirement that is expected to enhance U.S. national security through increasing the difficulty involved for harmful actors to exploit opaque legal structures for laundering money, financing...more
Following the enactment of the Anti-Money Laundering Act of 2020 (AMLA), which encompasses the Corporate Transparency Act (CTA), the Financial Crimes Enforcement Network (FinCEN) published an Advance Notice of Proposed...more
The Regulation Process for FinCEN’s New Beneficial Ownership Reporting Requirement Launches - The Financial Crimes Enforcement Network (FinCEN) issued an Advanced Notice of Proposed Rulemaking (ANPRM) on Thursday to solicit...more
Over the past few years, the National Highway Traffic Safety Administration (NHTSA), the primary regulator of motor vehicles and motor vehicle equipment and their manufacturers, has been balancing its work of keeping pace...more
The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has published an Advance Notice of Proposed Rulemaking (the Proposed Rule) seeking input from the public on the implementation of a reporting...more
On September 17, 2020, the Financial Crimes Enforcement Network (FinCEN) published an Advance Notice of Proposed Rulemaking (ANPR) in the Federal Register, seeking comments on how to improve the effectiveness of anti-money...more
In furtherance of the PFAS Action Plan of 2019, the Environmental Protection Agency (“EPA”) is adding certain per-and polyfluoroalkyl substances (“PFAS”) to the list of toxic chemicals subject to reporting under the Toxic...more
Seyfarth Synopsis: On December 20, 2019, the National Defense Authorization Act for Fiscal Year 2020 (NDAA) was signed into law, including provisions for adding certain per- and polyfluoroalkyl substances (PFAS) to the EPA’s...more
On Thursday, December 12, 2019, the OCC and the FDIC issued a notice of proposed rulemaking (NPR) in an effort to modernize the regulatory framework behind the Community Reinvestment Act (CRA). Last autumn, renewed...more
The U.S. Department of Transportation (DOT) has issued a notice of proposed rulemaking (NPRM) to amend its regulations governing situations in which an aircraft remains on the airport tarmac without an opportunity for...more
The fourth quarter of 2016 has seen an uptick in regulatory activity respecting the financial services sector in the cybersecurity space, both at the state level as previously discussed (here) and on the federal level....more