News & Analysis as of

Interim Final Rules (IFR) Due Diligence

WilmerHale

BIS Issues Export Control Compliance Requirements for Semiconductor Fabricators

WilmerHale on

On January 15, 2025, BIS issued an interim final rule controls targeting integrated circuits (“ICs”) fabricators. BIS is concerned that some IC designers have misrepresented the performance capabilities and intended end use...more

ArentFox Schiff

Sleeper Trump Rule on ‘Military-Intelligence End Uses or Users’ Goes Into Effect

ArentFox Schiff on

Companies should be prepared to conduct additional due diligence for any transactions involving entities in the countries enumerated in this rule. In an interim rule published on, January 15, 2020, the Department of...more

Goodwin

OCC Proposes Rules for CRA Benchmarks and Fair Access

Goodwin on

In the News. The Office of the Comptroller of the Currency (OCC) issued a long-awaited rule seeking comment on its proposed approach to determine the Community Reinvestment Act (CRA) evaluation measure benchmarks, retail...more

Buchalter

Buchalter COVID-19 Client Alert: Entrapment-by-Estoppel: A Potential Future Defense for Lenders in PPP Fraud Cases

Buchalter on

The past decade has taught lenders much about regulatory enforcement risk. In the fallout of the 2008 financial crisis and collapse of the housing and related markets, the Department of Justice and other agencies...more

Goodwin

Financial Services Weekly Roundup: Madden Fix/Valid When Made Rule Faces New Challengers

Goodwin on

In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more

Foley & Lardner LLP

FinCEN Issues Updated Guidance for Due Diligence of Hemp Businesses

Foley & Lardner LLP on

The Financial Crimes Enforcement Network (“FinCEN”) recently released guidance for bank and financial institutions regarding the requirements and obligations for financial institutions under the Bank Secrecy Act (BSA) and...more

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