News & Analysis as of

Enforcement Actions Proposed Rules Compliance

K&L Gates LLP

NFA Proposes Guidance on Diligent Supervision of Associated Persons

K&L Gates LLP on

UPDATE: On 1 May 2025, NFA withdrew Interpretive Notice 9083. The guidance remains available on NFA’s website for industry participants’ review....more

Zuckerman Spaeder LLP

Examining the United States Sentencing Commission’s Recent Voting History for Insight into its 2025 Term

Zuckerman Spaeder LLP on

At the American Bar Association’s White-Collar Crime Institute’s conference held in Miami, Florida on March 6-7, 2025, two panelists from the panel “Sentencing: Effective Mitigation in White-Collar Cases” differed on whether...more

Nilan Johnson Lewis PA

Pay Data Reporting – Off the Hook or Temporary Reprieve?

Nilan Johnson Lewis PA on

In 2016, the EEOC announced big changes to EEO-1 reporting. The new initiative, led by Obama-era appointees, required employers to report an entirely new category of data covering pay and hours worked for the purpose of...more

Kohrman Jackson & Krantz LLP

The Treasury Department Introduces a New Twist in the CTA Saga

On March 2, 2025, the U.S. Department of Treasury threw a new twist into the ongoing Corporate Transparency Act (CTA) enforcement saga by announcing that it will not enforce any fines or penalties against any U.S. citizens or...more

Vinson & Elkins LLP

FinCEN and the U.S. Treasury Department Suspend CTA Enforcement – Forthcoming Rule to Narrow CTA Compliance to Foreign Reporting...

Vinson & Elkins LLP on

On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced a suspension of enforcement actions related to the Corporate Transparency Act (“CTA”). This announcement means that reporting companies are...more

Allen Matkins

Navigating the Changing Landscape of Corporate Transparency Act Compliance

Allen Matkins on

Both the U.S. Department of the Treasury and FinCEN, a bureau within the Treasury Department, have issued statements, which, taken together, indicate a significant reduction in the enforcement of the Corporate Transparency...more

Weintraub Tobin

Corporate Transparency Act Update: Treasury Department Suspends Enforcement of CTA for U.S. Companies and Announces Upcoming Rule...

Weintraub Tobin on

On March 2, 2025, the U.S. Department of the Treasury announced a major shift in its approach to the Corporate Transparency Act (“CTA”). The Treasury Department stated that it will not enforce any penalties or fines related...more

Lowenstein Sandler LLP

FinCEN Announces No Fines or Penalties Under the CTA Pending New Rulemaking, New Narrowed Enforcement Scope

As discussed in our prior client alert, following the February 18 decision by the U.S. District Court for the Eastern District of Texas in Smith v. U.S. Dep’t of Treasury to stay a nationwide injunction it previously entered...more

Proskauer Rose LLP

Treasury Announces Non-Enforcement of the Corporate Transparency Act for Domestic Entities

Proskauer Rose LLP on

On March 2, 2025, the U.S. Department of the Treasury issued a press release announcing that it would not enforce any penalties or fines or take other enforcement actions against U.S. citizens or domestic reporting companies...more

Foley & Lardner LLP

Treasury Department Announces Suspension of Enforcement of Corporate Transparency Act Against U.S. Citizens and Domestic Reporting...

Foley & Lardner LLP on

The Treasury Department announced plans to significantly narrow beneficial ownership information (BOI) reporting obligations under the Corporate Transparency Act (CTA)....more

Ruder Ware

Hello, Goodbye: CTA Enforcement Suspended

Ruder Ware on

The U.S. Department of the Treasury suspended enforcement of the Corporate Transparency Act (CTA) for U.S. citizens and domestic reporting companies. On Sunday night, the Treasury announced that U.S. citizens and domestic...more

Cole Schotz

CTA is Effectively on Pause (Again)

Cole Schotz on

On Thursday, February 27, 2025, FinCEN announced that it will not issue any fines or penalties or take any enforcement actions against companies based on the failure to file or update beneficial ownership information (“BOI”)...more

Snell & Wilmer

The Corporate Transparency Act Update: A Reprieve for American Businesses?

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In another twist as to the future of the Corporate Transparency Act’s (CTA) implementation and judicial intervention, on February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not be...more

ArentFox Schiff

The CTA: Now You See It … Now You Don’t

ArentFox Schiff on

As the flurry of Corporate Transparency Act (CTA) developments continues, on March 2, the US Department of the Treasury (Treasury) announced the suspension of CTA enforcement against US citizens and domestic reporting...more

Hinshaw & Culbertson LLP

UPDATE: FinCEN Pauses Penalties for CTA Reporting Noncompliance and Signals Additional Changes

As discussed in our previous alert, in connection with the recent reinstatement of the Corporate Transparency Act (CTA) and its reporting obligations, FinCEN issued an announcement (the "Prior Announcement") extending the...more

Foley & Lardner LLP

FinCEN Not Issuing Fines or Penalties in Connection with Beneficial Ownership Information Reporting Deadlines for Now

Foley & Lardner LLP on

FinCEN announced that it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership information (BOI) reports pursuant to the...more

Snell & Wilmer

FARA's Pendulum: Shifts in Foreign Agent Regulation

Snell & Wilmer on

On her first day in office, Attorney General Pamela Bondi issued a memorandum signaling a significant shift in the Department of Justice’s (DOJ) approach to Foreign Agents Registration Act (FARA) enforcement. The memorandum...more

Davis Wright Tremaine LLP

New Administration Outlook: A Possible Roadmap to What's Ahead for the CFTC Under New Leadership

On January 20, 2025, the Commodity Futures Trading Commission ("CFTC") unanimously elected Commissioner Caroline D. Pham as acting chairman. The Administration has not yet identified who will be nominated for the position of...more

Morgan Lewis

DOJ’s Latest Attempt at Modernizing FARA Signals Greater Focus on Compliance and Enforcement

Morgan Lewis on

Following a decade of increased enforcement of what has been considered an oft-confusing law, the Department of Justice recently published a Notice of Proposed Rulemaking proposing several changes to regulations implemented...more

Husch Blackwell LLP

CBP Proposes Changes to the De Minimis Entry Process

Husch Blackwell LLP on

U.S. Customs and Border Protection (CBP) issued a Notice of Proposed Rulemaking on January 13, 2025, regarding an update to the rules governing de minimis shipments. The public can make comments on the proposed rule until...more

Hudson Cook, LLP

CFPB Bites of the Month - July 2024 - The CFPB Shines Like the 4th of July

Hudson Cook, LLP on

In this month's article, we share some of our top "bites" for the prior and current month covered during the July 2024 webinar....more

Skadden, Arps, Slate, Meagher & Flom LLP

Understanding SEC’s Focus Amid Lack of Final AI Rules

Last year, the U.S. Securities and Exchange Commission (SEC) proposed ambitious rules relating to artificial intelligence (AI) that have drawn significant commentary and criticism. While it is unlikely that any changes in the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - November 2023

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

Dorsey & Whitney LLP

RIA Regulatory Review - October 2023

Dorsey & Whitney LLP on

This RIA Regulatory Review highlights certain key regulatory developments affecting investment advisers. Please contact us with any questions on the topics covered below. The SEC Adopts Significant New Rules for Private...more

ArentFox Schiff

CMS Proposed Rule for Minimum Staffing Requirements in Long-Term Care Facilities

ArentFox Schiff on

On September 1, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule titled “Minimum Staffing Standards for Long-Term Care (LTC) Facilities and Medicaid Institutional Payment Transparency...more

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