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Holland & Knight LLP

FinCEN Issues Final Rule Implementing Access and Safeguard Provisions of the CTA

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The Corporate Transparency Act (CTA) was enacted in 2021 and became effective on Jan. 1, 2024. The CTA was passed with the aim of enhancing transparency in corporate ownership, so as to combat the proliferation of anonymous...more

Arnall Golden Gregory LLP

Three-Pronged Approach: The NDAA Prioritizes a Pro-Domestic Procurement Policy

On January 1, 2021, the National Defense Authorization Act for Fiscal Year 2021 (“NDAA”) was passed by Congress and became law, following an attempted veto by former President Donald Trump. The NDAA’s primary purpose is to...more

Arnall Golden Gregory LLP

“Modernized” and “Improved” Systems and Processes: How the Anti-Money Laundering Act of 2020 Changes the Landscape for Government...

With bipartisan support and overriding (for the first and only time during the Trump presidency) a presidential veto, Congress passed the National Defense Authorization Act (“NDAA”) on January 1, 2021.1  As part of the NDAA,...more

Ballard Spahr LLP

PPP Lenders and Fraudulent Borrowers: False Claims Act Liability and AML Risk

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Can BSA/AML Requirements Lead to Deemed Knowledge of Borrower Fraud? The first two weeks of August brought a milestone of sorts in the ongoing recovery from the economic downturn brought on by the COVID-19 pandemic. The...more

Cooley LLP

Blog: WSJ Reports SEC Enforcement Looking At Failures To Disclose Alliances Among Hedge Fund Activists

Cooley LLP on

The WSJ reports that the SEC is investigating whether some hedge fund activists formed 13D “groups” but failed to make appropriate disclosure of their alliances. Under Rule 13d-5, when two or more persons agree to act...more

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