News & Analysis as of

Final Rules Compliance

Baker Donelson

DOJ Final Rule Casts Wider Net: Common Business Data May Now Trigger National Security Scrutiny

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If you thought your company's collection of email address, IP address, zip code, birth date, or cookie data was too mundane to catch the federal government's attention – think again. Effective April 8, 2025, a new DOJ final...more

King & Spalding

CMS Issues New Guidance and Request for Information on Hospital Price Transparency Regulations

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Last week, CMS published new guidance and issued a Request for Information on the Hospital Price Transparency Rule in response to President Trump’s February 25, 2025 Executive Order titled, “Making America Healthy Again by...more

K&L Gates LLP

EPA Provides Update on PFAS Drinking Water Standards

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On 14 May 2025, Environmental Protection Agency (EPA) Administrator Lee Zeldin announced the agency’s plan to address the National Primary Drinking Water Regulations (NPDWR) for per- and polyfluoroalkyl substances (PFAS)...more

Venable LLP

Government Issues Nonenforcement Statement on Mental Health Parity Rules

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The government recently stated that it will delay enforcement of the 2024 final rules on the Mental Health Parity and Addiction Equity Act (MHPAEA). (Our previous alert regarding the 2024 final rules can be found here.) This...more

Winstead PC

The Federal Trade Commission (FTC) Click-to-Cancel

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The Federal Trade Commission (“FTC”) has recently announced that the FTC’s Click to Cancel Rule (the “Rule”) has been postponed to July 14, 2025. Originally planned to become effective May 14, 2025, the Commission released...more

Katten Muchin Rosenman LLP

Have You Done Your Part to Comply with Part 2 Changes?

Important changes are coming to 42 CFR Part 2 (Part 2), which deals with the confidentiality of patients’ substance use disorder (SUD) records. On April 16, 2024, the US Department of Health and Human Services (HHS) published...more

Jenner & Block

Client Alert: Myth Busters: Dispelling Common Misconceptions of the Department of Justice’s Data Security Program

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A month has passed since the Department of Justice (DOJ) National Security Division’s (NSD) issued its Final Rule prohibiting certain transactions involving US government data and Americans’ bulk sensitive personal data....more

Latham & Watkins LLP

FTC’s Click-to-Cancel Rule to Take Effect on May 14, 2025, Despite Litigation

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Companies with B2C or B2B recurring payment programs that include negative option terms should review their disclosure, consent, and cancellation practices to ensure compliance with the rule....more

Eversheds Sutherland (US) LLP

Navigating new compliance requirements for DOJ’s Bulk Data Rule

While the US federal government is largely scaling back its rulemaking and compliance efforts, one critical exception is where personal data and technology intersect with national security. Exemplifying this trend, on April...more

Foley & Lardner LLP

Is Your Company Prepared for the FTC’s Junk Fees Rule, Effective May 12?

Foley & Lardner LLP on

On May 5, 2025, the Federal Trade Commission (FTC or “the Commission”) published FAQs aimed at providing consumers and businesses with information regarding the agency’s Rule on Unfair or Deceptive Fees (the “Junk Fees Rule”...more

Perkins Coie

DOJ’s Bulk Personal Data Rule Becomes Effective–Resources for Compliance

Perkins Coie on

The new Department of Justice (DOJ) rule governing international transfers of Americans’ information, codified at 28 C.F.R. Part 202, became effective on April 8, 2025....more

ArentFox Schiff

Navigating the DOJ’s New Data Transfer Rule: Implications and Compliance Requirements

ArentFox Schiff on

On January 8, the US Department of Justice (DOJ) issued a final rule under Executive Order 14117, which established the Rule Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of Concern...more

Davis Wright Tremaine LLP

DOJ Issues Guidance on Foreign Data Access Rule, Announces Conditional 90-Day Enforcement Pause for "Good Faith Efforts"

The Department of Justice (DOJ) has issued guidance on its recently effective rule targeting foreign adversaries that "use commercial activities to access, exploit, and weaponize U.S. Government-related data and Americans'...more

Mayer Brown

Department of Justice Releases Compliance & Enforcement Guidance on Data Security Program

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On April 11, 2025, the Department of Justice (DOJ) announced additional guidance regarding the implementation of the Final Rule (the “Rule”), Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and...more

Ropes & Gray LLP

DOJ Releases FAQs and Compliance Guidance for Final Rule Restricting Flow of Bulk Sensitive Personal Data to China and other...

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On April 11, 2025, the Department of Justice (“DOJ”) released additional detail regarding the Final Rule implementing former President Biden’s Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal...more

Baker Donelson

DOJ Final Rule Targets Cross-Border Data Transfers: Key Implications for U.S. and Foreign-Owned Companies Operating in the U.S.

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In the final days of the Biden administration the U.S. Department of Justice (DOJ) issued a sweeping set of regulations which are in effect as of yesterday, April 8, 2025. The regulations focus on cross-border data transfers...more

Dickinson Wright

FinCEN Narrows CTA Reporting Requirements

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) released an Interim Final Rule (the Interim Rule), which served to “narrow” the existing beneficial ownership information (BOI) reporting requirements of...more

Faegre Drinker Biddle & Reath LLP

Humanitarian Parole for Cubans, Haitians, Nicaraguans and Venezuelans (CHNV) Terminated

Effective immediately, the termination of the humanitarian parole program for Cubans, Haitians, Nicaraguans and Venezuelans (CHNV) affects all beneficiaries who were granted protection from removal and work authorization for...more

Proskauer Rose LLP

New Interim Rule Removes CTA Reporting Requirements for U.S. Companies and U.S. Persons

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On March 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule to the U.S. Corporate Transparency Act (“CTA”) that eliminates beneficial ownership...more

McCarter & English, LLP

The Evolution of the CTA: FinCEN Removes Beneficial Ownership Reporting Requirements for US Companies and US Persons, Sets New...

On March 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced it is issuing an interim final rule to remove the Corporate Transparency Act’s (CTA) beneficial ownership...more

Whiteford

Client Alert: FinCEN Narrows CTA Scope - Key Updates

Whiteford on

On March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury, issued an interim final rule (the “Interim Rule”) under the Corporate Transparency Act (“CTA”) whereby...more

Chambliss, Bahner & Stophel, P.C.

CTA Reporting Rule Narrowed to Foreign Companies Only

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) released its anticipated interim final rule for the Corporate Transparency Act (CTA)...more

Akin Gump Strauss Hauer & Feld LLP

HHS, FDA Announce Multiple Initiatives on Food Safety, Quality and Compliance Fronts

In the past week, the U.S. Food and Drug Administration (FDA), in collaboration with the Department of Health and Human Services (HHS) announced three new initiatives related to food safety and food supply chain transparency....more

Downs Rachlin Martin PLLC

Corporate Transparency Act – FinCEN Announces Domestic Reporting Companies Exempt From Filing

As promised, in order to reduce the burdens on placed on legitimate businesses, while still working to detect, prevent, and prosecute financial crimes, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN)...more

Lowenstein Sandler LLP

FinCEN’s Weekend Present: No More CTA for U.S. Companies

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As discussed in our March 4 Client Alert, following its February 27 and March 2 announcements suspending enforcement of the Corporate Transparency Act (CTA) and promising additional CTA compliance guidance, on the evening of...more

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