News & Analysis as of

Final Rules Compliance Enforcement Actions

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

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

Mayer Brown on

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...

Ropes & Gray LLP on

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

Jackson Lewis P.C.

USCIS Issues Regulation Requiring Alien Registration

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On March 12, 2025, USCIS issued an Interim Final Regulation (IFR) designating a new registration form to comply with statutory alien registration and fingerprinting provisions. The IFR goes into effect on April 11, 2025....more

Mintz - Health Care Viewpoints

FDA’s Backup LDT Enforcement Method: Specimen Collection Kits

We have written at length about the U.S. Food and Drug Administration’s (FDA’s) actions to promulgate regulations specifying the agency’s authority to regulate laboratory developed tests (LDTs) as medical devices and to phase...more

Mintz - Energy & Sustainability Viewpoints

Sustainable Energy & Infrastructure CTA Updates — March 2025

FinCEN announced on February 27, 2025, that it will not impose fines or penalties for failures to file or update beneficial ownership information (BOI) reports in connection with the Corporate Transparency Act by the current...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

Moritt Hock & Hamroff LLP

The Treasury Department Announces Suspension Of Enforcement Of Corporate Transparency Act Against U.S. Citizens & Domestic...

In a significant development, on March 2, 2025, the U.S. Department of the Treasury (the “Treasury Department”) announced that, not only will the Treasury Department not enforce any penalties or fines associated with the...more

Wiley Rein LLP

FCC Expands Call Blocking Requirements for Voice Service Providers

Wiley Rein LLP on

On February 27, 2025, the Federal Communications Commission (FCC or Commission) adopted an Eighth Report and Order (Order) expanding the Commission’s rules targeting illegal robocallers. The Order extends the requirement to...more

Vorys, Sater, Seymour and Pease LLP

Corporate Transparency Act Deadlines Extended

On February 27, 2025, the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a release announcing that it intends to issue an interim final rule by March 21, 2025 that will extend the current deadlines to file or...more

Buckingham, Doolittle & Burroughs, LLC

FinCEN Temporarily Pauses Enforcement of Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act

On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not impose fines, penalties, or other enforcement actions against companies for failing to file or update beneficial ownership...more

Perkins Coie

New US Commerce Prohibitions on Chinese and Russian Connected Vehicle Technology

Perkins Coie on

New security rules designed to protect the connected vehicle supply chain will take effect in March unless they are withdrawn. The U.S. Department of Commerce Bureau of Industry and Security (BIS) published the final rule...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

Proskauer Rose LLP

Corporate Transparency Act Deadlines on Hold

Proskauer Rose LLP on

On February 27, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced that it would not issue any fines or penalties or take other enforcement actions for a failure to comply...more

Neal, Gerber & Eisenberg LLP

Corporate Transparency Act is Again on Hold

On February 27, 2025, 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)...more

McGlinchey Stafford

FinCEN Announces No Penalties for BOI Reporting Failures

McGlinchey Stafford on

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

Husch Blackwell LLP

Eastern District of Kentucky Tolls Compliance Deadlines for § 1033 of the Dodd-Frank Act

Husch Blackwell LLP on

On February 25, 2025, Judge Danny C. Reeves of the Eastern District of Kentucky granted a Joint Motion to Stay Proceedings in Forcht Bank, NA et al v. Consumer Financial Protection Bureau et al, temporarily staying litigation...more

IR Global

SB24-231: Major Updates to Colorado Liquor Laws

IR Global on

As of January 1, 2025, the Colorado Department of Revenue’s Liquor and Tobacco Enforcement Division implemented new liquor rules to enforce SB24-231, which became law in 2024. The new law vastly modified the alcohol industry...more

Sheppard Mullin Richter & Hampton LLP

Fifth Circuit Strikes Down FTC’s ‘Junk Fee’ Rule for Auto Dealers

On January 24, 2025, the Fifth Circuit Court of Appeals struck down an FTC rule aimed at curbing deceptive advertising and sales practices in the auto industry. The rule, which sought to prohibit certain “junk fees” and...more

BCLP

FCC’s New 1:1 Consent Rule Spells Trouble in 2025

BCLP on

On January 27, 2025, the new Federal Communications Commission (“FCC”) rule requiring telemarketers to obtain one-to-one consent for robocalls/texts is scheduled to go into effect. Expanding on the Telephone Consumer...more

Latham & Watkins LLP

Unpacking the FTC’s New Negative Option Rule, Its Legal Challenges, and Future Uncertainty

Latham & Watkins LLP on

The rule impacts both B2B and B2C subscription autorenewals and other negative option programs; however, significant legal challenges could impact the rule’s implementation....more

Husch Blackwell LLP

MSHA/OSHA Civil Penalty Amounts Increase for 2025

Husch Blackwell LLP on

On January 10, 2025, the Department of Labor’s annual penalty adjustments were published in the Federal Register. The 2025 increases are approximately 2.6%.  The chart below applies to any penalties assessed after January 15,...more

Wiley Rein LLP

FCC Strengthens RMD Filing Requirements and Enforcement Capability

Wiley Rein LLP on

On January 8, 2025, the Federal Communications Commission (FCC or Commission) released a Report and Order (Order) adopting new rules for Robocall Mitigation Database (RMD) filings. Adopted unanimously by the Commission, the...more

Bradley Arant Boult Cummings LLP

FTC’s “Click to Cancel” Rule to Simplify Subscription Cancellations Becomes Effective

The final text of the amended Negative Option Rule, featuring the new “Click to Cancel” program, goes into effect this week on Wednesday, January 15, 2025, and should become enforceable approximately four months later on...more

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