News & Analysis as of

Constitutional Challenges Reporting Requirements

Baker Donelson

Red Tape or Green Future? Unpacking California's Climate Disclosure Laws and the Pushback

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As the federal government works to roll back climate regulations and climate-focused initiatives, states are developing avenues to fill in the gaps left behind. In 2024, the Securities and Exchange Commission (SEC) adopted...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Update on Missouri’s Proposition A: Status of Earned Paid Sick Time Law

Employers must provide notice of Missouri’s new earned paid sick time (PST) requirements no later than April 15, 2025—ahead of the May 1, 2025, effective date of the state’s new PST law, or Proposition A, passed by voters in...more

Lathrop GPM

Dept. of Education Certification Requirement Tied to “Antidiscrimination Obligations” for Continued K-12 Federal Funding

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On April 3, 2025, the U.S. Department of Education (ED) issued a press release announcing the ED sent certification letters to state commissions that oversee K-12 State Education Agencies (SEAs), charging SEAs with the...more

Thomas Fox - Compliance Evangelist

FCPA Compliance Report: Death of CTA

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode, Tom welcomes back Corporate Transparency Act expert and maven Jonathan Wilson for a look at how the Trump...more

Wilson Sonsini Goodrich & Rosati

SEC Votes to End Defense of Climate Disclosure Rules

On March 27, 2025, the SEC announced that it voted (2-1) to end its defense of the final enhanced and standardized climate-related disclosure rules (the Climate Rules). The SEC previously adopted the Climate Rules on March 6,...more

McNees Wallace & Nurick LLC

Closing Call for the Corporate Transparency Act: FinCEN Removes Reporting Requirements for Domestic Business Entities

After almost fifteen months of legal challenges, conflicting court rulings, changing guidance from the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN), and a general air of uncertainty, it appears...more

Cooley LLP

Surprise—not! SEC votes to terminate defense of climate disclosure rules

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Yesterday, the SEC announced that the Commissioners had voted to end the SEC’s “defense of the rules requiring disclosure of climate-related risks and greenhouse gas emissions”—the climate disclosure rules. As you probably...more

Morrison & Foerster LLP - Social Media

California’s Assembly Bill 587 Loses Key Provisions After Legal Challenge from X

California’s attempt to impose content moderation transparency requirements on social media platforms has suffered a significant setback. Last month, the state reached a settlement with X Corp. (formerly Twitter), effectively...more

Cozen O'Connor

Illinois Insights: An update from Cozen O'Connor (3/26)

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Illinois AG pushes for more funding amid legal battles with Trump administration- “Illinois Attorney General Kwame Raoul is pushing for additional funding for his office as it takes on a host of lawsuits and legal filings...more

Vinson & Elkins LLP

Federal Climate Change Disclosures No More

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In a move that perhaps comes as no surprise, on March 27, 2025, the Securities and Exchange Commission (“SEC” or “the Commission”) issued Press Release 2025-58 announcing it had voted to end its defense of its climate-related...more

Clark Hill PLC

Only Foreign Entities Need to Report Under the CTA

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN), a bureau of the Treasury Department, issued a new interim final rule on reporting under the Corporate Transparency Act (CTA). The new rule drastically...more

Holland & Hart LLP

FinCEN EXEMPTS U.S. Companies and U.S. Persons from CTA Reporting Requirements

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The Corporate Transparency Act (together with its implementing regulations, the CTA) is a federal law that went into effect on January 1, 2024. The CTA is aimed at combating financial crimes such as money laundering,...more

Perkins Coie

Corporate Transparency Act: FinCEN Releases Interim Rule Limiting Application of CTA to Foreign Companies Registered to Do...

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On March 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published the text of an interim rule formally revising the Corporate Transparency Act’s (CTA) definition of “reporting...more

Katten Muchin Rosenman LLP

US Treasury Issues Interim Final Rule That Removes the Requirement for US Companies and US Persons To Report Beneficial Ownership...

The Financial Crimes Enforcement Network (FinCEN) announced on March 21, 2025, that FinCEN had issued its Interim Final Rule that provides that FinCEN will not require US companies and US persons to report beneficial...more

Allen Matkins

Will Ling Chi Kill The Corporate Transparency Act?

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Ling Chi was a slow and torturous method of execution practiced in Imperial China.  Better known in English as "death by a thousand cuts", ling chi took a terribly long time to kill the condemned prisoner....more

White & Case LLP

US Supreme Court Rejects Application of Commingling Theory in Holocaust Expropriation Case

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On February 21, 2025, the US Supreme Court issued a unanimous decision in Republic of Hungary v. Simon, further narrowing the scope of the Foreign Sovereign Immunities Act's exception to sovereign immunity for expropriation...more

PilieroMazza PLLC

Court Blocks Suspension and Termination of Foreign Aid Contracts: Key Takeaways for Government Contractors

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In a landmark decision, Judge Ali has issued a preliminary injunction (PI) preventing the U.S. government from enforcing suspensions, stop-work orders, and terminations for foreign aid contracts issued between January 20 and...more

Saiber LLC

The Saiber Construction Law Column: February 2025

Saiber LLC on

The Corporate Transparency Act was passed in 2021 and took effect January 1, 2024. The purpose of the act is to help combat money laundering, fraud, and terrorism by requiring certain non exempt private companies to report...more

McNees Wallace & Nurick LLC

“The Corporate Transparency Act is Unconstitutional”, Whispered a Federal Court in Michigan

Days after the United States Treasury Department and its Financial Crimes Enforcement Network (FinCEN) announced it was suspending enforcement the Corporate Transparency Act (CTA), (you can read about that in our last client...more

Miller Canfield

Michigan Federal Court Holds CTA Reporting Rule Unconstitutional, Enjoins Enforcement Against Named Plaintiffs

Miller Canfield on

On March 3, 2025, a Michigan federal district court in Small Business Association of Michigan v Yellen, Case No. 1:24-cv-413 (W.D Mich 2025) (SBAM), held that the CTA’s reporting rule is unconstitutional under the Fourth...more

Foster Garvey PC

FinCEN Delivers Some Good News About Its Enforcement of the Corporate Transparency Act

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On Thursday, February 27, 2025, FinCEN announced that it will not issue any penalties or pursue enforcement action against reporting companies for the mere failure to meet the current filing deadlines. That news for many is...more

Wiley Rein LLP

Treasury Says It Won’t Enforce Corporate Transparency Act Against U.S. Companies or Citizens

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Treasury / FinCEN - Interim Final Rule and Proposed Rulemaking - On March 2, 2025, the U.S. Department of the Treasury issued a press release stating that it will not enforce any penalties or fines against U.S. citizens or...more

Kelley Drye & Warren LLP

Treasury Department Halts Enforcement of CTA Reporting Obligations

On March 2, 2025, the U.S. Treasury Department announced that it would not enforce penalties or fines associated with beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA)...more

Cozen O'Connor

FinCEN Pauses Enforcement Actions under CTA

Cozen O'Connor on

On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not take enforcement actions against any companies for failure to file or update beneficial ownership information (BOI) reports...more

Latham & Watkins LLP

Court Dismisses Portions of Lawsuit Against California Climate Disclosure Laws

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Supremacy Clause and Dormant Commerce Clause claims against SB 253 and SB 261 were dismissed, while claims under the First Amendment proceed to discovery....more

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