News & Analysis as of

New Rules Comment Period

Clark Hill PLC

Only Foreign Entities Need to Report Under the CTA

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN), a bureau of the Treasury Department, issued a new interim final rule on reporting under the Corporate Transparency Act (CTA). The new rule drastically...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update: FinCEN Eliminates Reporting Obligations for U.S. Companies and U.S. Persons

On March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule that significantly narrows the beneficial ownership information (“BOI”) reporting requirements under the Corporate...more

Butler Snow LLP

Proposed Rule Published Restricting Data Sharing with China, Russia, Iran, North Korea, Cuba, and Venezuela

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The US Department of Justice issued a Notice of Proposed Rule Making (NPRM) October 21, 2024 that, if finalized, will prohibit or restrict a significant amount of international data sharing with countries of concern,...more

Sheppard Mullin Richter & Hampton LLP

FCC Proposes New Rules Governing AI-Generated Robocalls

On August 8, 2024, the Federal Communications Commission (“FCC”) issued a Notice of Proposed Rulemaking (“NPRM”) to address the growing use of AI-generated robocalls. The FCC’s NPRM follows a 2023 inquiry proceeding into how...more

White & Case LLP

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

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On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

Torres Trade Law, PLLC

New BIS Rule Grants Australia and the UK “Nearly” the Same Treatment as Canada

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On April 19, 2024, the Department of Commerce Bureau of Industry and Security (“BIS”) published an interim final rule (“Interim Rule”), amending the Export Administration Regulations (“EAR”) to enhance cooperation and...more

Woods Rogers

Proposed Federal Cyber Incident Reporting Rule Adds Hefty Federal Reporting Requirements to Critical Infrastructure Sector and...

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The federal Cybersecurity and Infrastructure Security Agency (CISA) released a draft of its proposed rule detailing how covered entities operating in critical infrastructure sectors report cyberattacks and ransomware payments...more

WilmerHale

FCC Adopts New Robocall and Robotext Consent Rules Under TCPA

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On February 15, the Federal Communications Commission (FCC or “the Commission”) adopted a Report and Order and Further Notice of Proposed Rulemaking (“the Order”) pursuant to the Telephone Consumer Protection Act (TCPA) that...more

ArentFox Schiff

Calling all Cash Money Millionaires: FinCEN Proposes New Reporting Rules for Cash Residential Real Estate Transfers

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“In residential real estate sales, all parties involved, including sellers, developers, title companies, attorneys, and closing agents, need to be aware of reporting requirements. Consider a situation where a commercial...more

Proskauer - Labor Relations Update

Chamber of Commerce Lawsuit Pushes Back NLRB Joint-Employer Rule Start Date Again

On February 22, 2024, a judge in the Eastern District Court of Texas issued a stay which will delay the effective start date of the National Labor Relations Board’s (“NLRB”) new joint-employer rule by 14 days, from February...more

Womble Bond Dickinson

FCC Adopts New TCPA Rules Expanding Consumer Consent Revocation Mandates

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The FCC has adopted a Report and Order imposing a number of new TCPA caller and sender compliance obligations in connection with consumer revocation requests, which are applicable to calls and text messages that otherwise...more

Fenwick & West LLP

Commerce Department Proposes Sweeping Know Your Customer & Other Requirements for IaaS Providers

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The United States Department of Commerce (Commerce) issued a notice of proposed rulemaking (NPRM) seeking comments on new proposed regulations that would, if enacted, impose extensive Know Your Customer (KYC) and Customer...more

Nossaman LLP

Interior Issues New NRDAR Type A Rule for Comment

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On January 5, 2024, the Department of the Interior (Interior) will issue a notice of a proposed rulemaking (NPRM) to provide the first significant revisions to its natural resource damage assessment and restoration (NRDAR)...more

Robinson+Cole Data Privacy + Security Insider

FTC and CPPA Release Rules to Address AI Risks and Protect Consumer Rights

The rise of AI technology has prompted regulatory agencies to take action and protect consumers’ rights, as evidenced by the recent efforts of the Federal Trade Commission (FTC) and the California Privacy Protection Agency...more

Womble Bond Dickinson

FCC Beefs Up Robocall Guardrails for VoIP Number Access

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The FCC adopted new rules and proposed additional rules to modernize and strengthen its requirements for Voice over Internet Protocol (VoIP) providers to obtain direct access to telephone numbers in order to reduce access to...more

Bass, Berry & Sims PLC

Fifth Circuit Requires SEC to Revisit Share Repurchase Disclosure Rules

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On October 31, the U.S. Court of Appeals for the Fifth Circuit (Fifth Circuit) issued an opinion finding that the U.S. Securities and Exchange Commission (SEC) violated the Administration Procedure Act when adopting recent...more

Quarles & Brady LLP

DHS Proposes Rule to Modernize H-1B Program

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The Department of Homeland Security has published a Notice of Proposed Rule Making (NPRM or the Rule) entitled “Modernizing H-1B Requirements, Providing Flexibility in the F-1 Program, and Program Improvements Affecting Other...more

Bradley Arant Boult Cummings LLP

IRS Announces Transition Period for Roth Catch-Up Contributions

The Internal Revenue Service (IRS) has announced a two-year administrative transition period that delays until 2026 the new rule that catch-up contributions made by certain higher‑income participants in 401(k), 403(b), and...more

Jenner & Block

New EPA Rule Removes Emergency Defense Waiver in Title V Air Permits

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On July 21, 2023, the Environmental Protection Agency published a final rule eliminating an affirmative defense for Clean Air Act permit emissions violations caused by “emergency” circumstances. “Major sources” (i.e....more

Latham & Watkins LLP

FCC Aims to Expand Oversight of Foreign Ownership Interests in International Section 214 Authorization Holders

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Potential rule changes could expand the scope of the disclosure and reporting obligations for FCC-regulated businesses. On April 25, 2023, the Federal Communications Commission (FCC) released an Order and Notice of...more

Hogan Lovells

FCC to explore new rules for in-space servicing, assembly, and manufacturing missions

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The Federal Communications Commission (FCC) recently took the first steps toward new rules to govern the next frontier of space innovation by adopting a notice of inquiry on in-space servicing, assembly, and manufacturing...more

Hogan Lovells

SEC propõe novas regras sobre o formato de divulgação de informações sobre mudança climática

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Em 21 de março de 2022, a Comissão de Valores Mobiliários dos EUA (U.S. Securities and Exchange Commission ou “SEC”) propôs suas novas regras de divulgação de informações relacionadas a questões climáticas. As regras...more

Sheppard Mullin Richter & Hampton LLP

FinTechs in Crosshairs as CFPB Invokes Dormant Authority to Examine Nonbanks

On April 25, the CFPB announced that it is using its “dormant authority” in order to conduct examinations of nonbanks posing risks to consumers.  The Bureau has direct supervisory authority over banks and credit unions,...more

Goodwin

SEC Proposes New Rules Applicable To SPACs And Certain Reverse Mergers

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On March 30, 2022, the U.S. Securities and Exchange Commission (SEC or Commission) held an open meeting to consider proposed rules and amendments regarding special purpose acquisition companies (SPACs), shell companies, and...more

Kramer Levin Naftalis & Frankel LLP

SEC Proposes Cybersecurity Risk Management Requirements for Investment Advisers and Registered Funds

On Feb. 9, 2022, the Securities and Exchange Commission (SEC or Commission) proposed a suite of new rules and amendments concerning cybersecurity risk management for registered investment advisers (advisers) and registered...more

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