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National Security Penalties

Adams and Reese LLP

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more

Dechert LLP

Read All About It: CFIUS Publishes Enforcement Information

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After over a year of preview, the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) has finally published information on its most recent enforcement actions. The actions were announced on...more

Jones Day

CFIUS Annual Report Touts an Increase in Penalties and Efficiency in Transaction Reviews

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While the total number of filings declined in comparison to recent years, CFIUS's latest Annual Report to Congress highlights an uptick in penalties and an increased use of enforcement tools relating to national...more

Mintz

Three Key Takeaways from CFIUS's 2023 Annual Report

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The Committee on Foreign Investment in the United States (CFIUS) released its statutorily mandated annual report to congress last month. While the report itself highlights several notable developments in 2023 (New Zealand and...more

Holland & Knight LLP

Treasury Department Issues Proposed Rule to Enhance CFIUS Procedures, Enforcement Authorities

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Almost six years after the enactment of the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA), the U.S. Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (CFIUS),...more

Eversheds Sutherland (US) LLP

Treasury proposes expansion of CFIUS authorities

On April 11, 2024, the US Department of the Treasury issued, for notice and comment, proposed modifications (Proposed Rule) to certain Committee on Foreign Investment in the United States (CFIUS or Committee) regulations. In...more

Bass, Berry & Sims PLC

CFIUS Update: Larger Penalties, Sharper Monitoring

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On April 11, the U.S. Treasury Department promulgated a Notice of Proposed Rulemaking (NPRM) amending the regulations that govern the operations of the Committee on Foreign Investment in the United States (CFIUS) to increase...more

Torres Trade Law, PLLC

Less Bark and More Bite? CFIUS Proposed Rule Enhancing Enforcement Capabilities

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A new proposed rule issued by the Committee on Foreign Investment in the United States (CFIUS) seeks to expand the scope of information that CFIUS can request from parties, expand its ability to monitor and investigate...more

Akin Gump Strauss Hauer & Feld LLP

CFIUS Proposes Expanded Enforcement Authorities and Increased Penalties

Key Points - On April 15, 2024, the Treasury Department published a proposed rule that would amend the Committee on Foreign Investment in the United States (CFIUS) regulations to expand CFIUS’s enforcement authorities....more

Latham & Watkins LLP

Treasury Proposes New CFIUS Regulations to Expand Monitoring and Enforcement Authorities: 5 Key Takeaways

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The proposal signals a continued effort to expand CFIUS’s enforcement scope and update penalties. On April 11, 2024, the US Department of the Treasury (Treasury) issued a Notice of Proposed Rulemaking (the Proposed Rule)...more

Dechert LLP

CFIUS’ Proposed Rules Enhance its Enforcement Authority

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The U.S. Department of Treasury (“Treasury”), which is Chair of the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”), released a Notice of Proposed Rulemaking on April 11, 2024 (“NPRM”) meant...more

Wiley Rein LLP

Treasury Proposes Stronger CFIUS Penalties, Broader Subpoena and Enforcement Powers

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The U.S. Department of the Treasury (Treasury), which chairs the Committee on Foreign Investment in the United States (CFIUS or the Committee), recently published a Notice of Proposed Rulemaking (NPRM) that would amend the...more

Bracewell LLP

Beyond Whistleblowing: Additional Highlights From the Department of Justice at the 2024 ABA White Collar Conference

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As we wrote earlier this month, the Department of Justice (DOJ) made significant news at the recent American Bar Association White Collar Conference. But the Department didn’t stop at announcing its pilot whistleblower...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

Proskauer - Health Care Law Brief

The Corporate Transparency Act: Key Considerations for Health Systems and Practice Management Companies (MSOs/DSOs)

In 2021, Congress enacted the Corporate Transparency Act (the “CTA”) to “better enable critical national security, intelligence, and law enforcement efforts to counter money laundering, the financing of terrorism, and other...more

Akin Gump Strauss Hauer & Feld LLP

BIS Announces Key Updates to Voluntary Self-Disclosure Process

Key Points - On January 16, 2024, Matthew Axelrod, Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s BIS announced key updates to BIS’s VSD process. The updates are also now reflected on BIS’s...more

Downs Rachlin Martin PLLC

Corporate Transparency Act - New Federal Reporting Requirement For Entities

Background - In January 2021, the United States Congress passed the Corporate Transparency Act (CTA) as part of the Anti-Money Laundering Act of 2020. This law, while intended to prevent criminal actors from hiding and...more

Snell & Wilmer

The Uncertain World: Nearshoring, Economic Development, and the Next Frontier

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Historically, international trade regulation has swung between economic protectionism and national security concerns. Between World War II and the 2018 presidential election, the primary international trade regulatory issue...more

Proskauer - Regulatory & Compliance

CTA – Accessing Beneficial Ownership Information

On December 21, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued the final rule on Beneficial Ownership Information Access and Safeguards (the “Access Rule”) laying out the...more

Goodwin

FinCEN Issues Final Rule on Beneficial Ownership Information Access and Safeguards; Bank Regulators Issue Interagency Statement...

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On December 21, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (Access Rule) regarding access to the beneficial ownership information (BOI) reported to FinCEN...more

McGlinchey Stafford

Corporate Transparency Act Reporting Begins: Are You Ready?

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Effective January 1, 2024, companies must disclose their beneficial owners to the Financial Crimes Enforcement Network (FinCEN) within the United States Department of Treasury. The reporting requirement is part of the U.S....more

McDermott Will & Emery

Corporate Transparency Act: What to Know

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The Corporate Transparency Act (CTA) introduces beneficial ownership reporting requirements effective January 1, 2024, for new and existing companies. Below is an overview of the new reporting obligations imposed by the CTA....more

Husch Blackwell LLP

Corporate Transparency Act Guide

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On January 1, 2024, the Corporate Transparency Act (CTA) will go into effect, and if your business is deemed to be a Reporting Company under the CTA, the clock will begin ticking on new federal reporting obligations....more

Proskauer Rose LLP

Wealth Management Update - December 2023

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Shining a Light on the Corporate Transparency Act: FinCEN’s Rules for Beneficial Ownership Reporting - On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering...more

McDonnell Boehnen Hulbert & Berghoff LLP

European Union Agrees to Terms of Artificial Intelligence Act

After two-and-a-half years of negotiation disrupted by the rise of generative models, the European Parliament and the European Council have reached a provisional understanding of how artificial intelligence (AI) should be...more

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