Compliance Perspectives: Rolling Out New Compliance Initiatives
On April 17, 2025, the Securities and Exchange Commission (SEC) extended the expiration date of a no-action statement (Compliance Statement) regarding compliance with reporting rules for security-based swap data repositories...more
On April 22, 2025, the Federal Trade Commission published in the Federal Register the amendments to the Children’s Online Privacy Protection Act (COPPA) rule it announced on January 16, 2025. ...more
On May 1, 2025, additional enhanced cybersecurity controls required by the Second Amendment to the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) (the “Second Amendment”) take...more
2025 has already been a busy year in UK consumer protection law. With the CMA having issued its annual plan for 2025 / 2026 on 27 March 2025 and its new enforcement powers under the Digital Markets, Competition and Consumer...more
As part of a multiyear rollout, the New York Department of Financial Services (NYDFS) has established May 1, 2025, and November 1, 2025, as effective dates for certain amendments to its cybersecurity regulations. These...more
On April 10, 2025, the Food and Drug Administration (FDA) released a pre-recorded webinar outlining the updated "healthy" nutrient content claim rule. As we previously discussed, the rule will go into effect on April 28,...more
On April 7, 2025, the Federal Communications Commission (“FCC”) announced that it would delay portions of a significant new rule pertaining to the revocation of consumer consent under the Telephone Consumer Protection Act...more
The Maryland General Assembly passed a final bill on Apr. 7, 2025, postponing the implementation dates for Maryland’s Family and Medical Leave Insurance (FAMLI) program. The governor is expected to approve the bill soon,...more
On April 7, the Federal Communications Commission (FCC) issued an Order (Extension Order) granting a limited waiver that delays the effective date of certain portions of Section 64.1200(a)(10) of the FCC’s rules by one year –...more
Circular Action Alliance to accept reports through April 30, 2025 - Circular Action Alliance (CAA) recently announced a grace period through April 30, 2025 for producers to report data by weight and material category for all...more
Established under the Cyber Security Act 2024 (the ‘Act’), the Cyber Security (security standards for smart devices) Rules 2025 (the ‘Rules’) set out the requirements for three security standards introduced to enhance the...more
On March 14, 2025, the SEC announced a six-month extension of the compliance dates for its previously adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (known as the Names Rule). The compliance date is...more
On March 14, 2025, the Securities and Exchange Commission (SEC) issued the following press release (Release) to extend compliance with the amendments (Amendments) to Rule 35d-1 (Names Rule) under the Investment Company Act of...more
2025 is set to be a busy year in UK consumer protection law. With the CMA issuing its annual plan for 2025 / 2026 on 27 March 2025 and its new powers to enforce consumer protection law under the Digital Markets, Competition...more
Illegal content safety duties came into full effect on 17 March 2025, shortly followed by children’s access assessment requirements. The UK Online Safety Act (OSA) establishes an extensive regulatory framework for...more
Starting today, March 17, 2025, new U.S. regulations impose sweeping restrictions on the importation and sale of connected vehicles (CV) and related components with ties to China and Russia....more
The Federal Deposit Insurance Corporation (FDIC) is further postponing the compliance date requirements to display the FDIC official digital sign on an insured depository institution’s (IDI) digital channels, as well as on...more
In a release dated March 2, 2025, the Treasury Department has indicated that all enforcement of the Corporate Transparency Act (the “CTA”) against United States citizens and domestic reporting companies will be suspended,...more
The CTA is not dead, but it is hanging by a thread. On March 2, the U.S. Treasury Department (the Treasury) issued a press release announcing significant updates to the plans announced by FinCEN just a few days earlier....more
Although the Corporate Transparency Act (the “CTA”) remains in full force and effect and, along with it, a requirement for most reporting companies to file their beneficial ownership information reports, the previously...more
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
Long IT sub-contracting chains can make it hard for financial institutions to understand the vulnerabilities in their IT estate and the location of key functions (where these may be located in entities who do not have a...more
The Online Safety Act (the OSA) received Royal Assent on 26 October 2023 and is now in force. The OSA establishes an extensive regulatory framework for providers of online user-to-user services and search services with...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on July 26, 2024, issued a notice containing a reference guide for customers of financial institutions (the Reference Guide). The Reference...more
Recent client alerts have provided an overview of the new “private fund rules” adopted in late August by the U.S. Securities and Exchange Commission (SEC). These rules apply, subject to limited exceptions and carveouts, to...more