On January 14, 2025, just six days before the transition from the Biden Administration to the second Trump Administration, OSHA closed the books on collecting public comments on the agency’s Notice of Proposed Rulemaking...more
In a previous post, we discussed the Federal Deposit Insurance Corporation’s (FDIC) notice of proposed rulemaking aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank...more
On October 21, 2024, the U.S. Department of Justice (Department or DOJ) and the U.S. Department of Homeland Security’s (DHS) Cybersecurity and Infrastructure Security Agency (CISA) issued proposals – required by the...more
On September 17, 2024, the FDIC board approved a notice of proposed rulemaking that would increase recordkeeping obligations for bank deposits received from third party, non-bank companies that accept those deposits on behalf...more
Our Financial Services Team studies the Federal Deposit Insurance Corporation’s plans to require insured depository institutions (IDIs) to keep specific records so that they know the actual owner of deposits placed by...more
The Federal Deposit Insurance Corporation (“FDIC”) proposed in its Notice of Proposed Rulemaking (“NPR”) that insured IDIs keep records of individual accounts that are typically held in pooled custodial accounts that support...more
On June 10, 2024, the Federal Communications Commission (FCC or Commission) released a Notice of Proposed Rulemaking (NPRM) seeking comment on revisions to Commission rules related to the Low Power Television (LPTV) Service,...more
I. INTRODUCTION - On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the...more
During the FIBA’s (Financial and International Business Association’s) annual anti-money laundering conference held from March 18, 2024, to March 21, 2024 in Miami, Florida, Director Gacki from FinCEN discussed regulatory...more
The U.S. Department of Homeland Security’s (DHS) Cybersecurity and Infrastructure Security Agency (CISA) is publishing a proposed rule (Proposal or NPRM) that will require broad segments of industry to meet onerous and quick...more
In July 2020, a sensitive Federal Bureau of Investigation (FBI) document was leaked to the public. The document outlined the FBI’s suspicions that the private investment funds industry was providing choice money laundering...more
On February 16, the Financial Crimes Enforcement Center (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”) regarding residential real estate. The final version of the NPRM published in the Federal Register is 47...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a new notice of proposed rulemaking (NPRM), referred to herein as the "Proposed Rule," that would subject SEC-registered...more
The United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a notice of proposed rulemaking (NPRM) that would subject registered investment advisers (RIAs) and exempt reporting...more
On October 23, the Financial Crimes Enforcement Network (“FinCEN”) published a notice of proposed rulemaking (“NPRM”) entitled Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of...more
On October 19, 2023, The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM) taking aim at convertible virtual currency (CVC) mixing transactions,...more
The U.S. Environmental Protection Agency (EPA) on July 27, 2023, published its Semiannual Regulatory Agenda, which is intended to update the public about the agency's plan to review, propose and issue regulations over the...more
October 26, 2021 Update: Following up on the short-term extension that it issued in September, EPA has issued a notice of proposed rulemaking that will further extend the compliance deadline for the processing and...more
The Department of Labor (DOL) is publishing a Notice of Proposed Rulemaking (NPRM) detailing proposed regulations implementing new minimum wage requirements that certain federal contractors must pay workers performing work...more
EEOC Releases Vaccine Guidance. On May 28, 2021, the U.S. Equal Employment Opportunity Commission (EEOC) issued much-needed guidance regarding COVID-19 vaccinations and the workplace. According to the guidance...more
A controversial proposed rule from the Financial Crimes Enforcement Network would bring bank-like regulation of virtual asset transactions, including the first broadly-applied AML reporting requirement in at least two...more
On December 18, 2020, the Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) to establish new requirements for convertible virtual currency (CVC) and legal tender digital asset (LTDA)...more
A new proposed rulemaking (the “NPRM”) would lower the current $3,000 threshold for the applicability of the Bank Secrecy Act (“BSA”) Recordkeeping Rule and Travel Rule to $250 for covered funds transfers that begin or end...more
The proposed changes seek to formally rescind the Obama Administration’s 2016 Final Rule, which more than doubled the minimum salary levels for exemption for overtime requirements. Instead, the Trump Administration proposes...more
In 2016, the Obama administration’s Occupational Safety and Health Administration issued regulations requiring certain companies to electronically file annual employee occupational illness and injury information. This...more