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Berkshire

2024 EEO-1 Reporting Update

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The 2024 EEO-1 Component 1 data collection appears to be moving forward, according to documents recently submitted for approval by the White House Office of Management and Budget (OMB). According to the proposed 2024 EEO-1...more

Brooks Pierce

Corporate Transparency Act: FinCEN and the Treasury Announce Nonenforcement for Domestic Reporting Companies

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Following announcements from the Financial Crimes Enforcement Network (“FinCEN”) on February 27, 2025, and the United States Department of the Treasury (the “Treasury”) on March 2, 2025, it would appear that beneficial...more

Weintraub Tobin

Corporate Transparency Act Update: Treasury Department Suspends Enforcement of CTA for U.S. Companies and Announces Upcoming Rule...

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On March 2, 2025, the U.S. Department of the Treasury announced a major shift in its approach to the Corporate Transparency Act (“CTA”). The Treasury Department stated that it will not enforce any penalties or fines related...more

Spilman Thomas & Battle, PLLC

Treasury Department Announces Suspension of Enforcement of Corporate Transparency Act Against U.S. Citizens and Domestic Reporting...

After months of back-and-forth regarding the status of the Corporate Transparency Act (“CTA”), the U.S. Department of Treasury has effectively ended the CTA’s reporting obligations for U.S. citizens and domestic reporting...more

Hinckley Allen

Navigating Profound Change: CISA Announces Proposed Rule for Mandated Cyber Incident Reporting

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In 2025, new federal reporting requirements will require hundreds of thousands of organizations to report cyber incidents within hours of discovery to the United States Government, marking a significant impact on how...more

Ankura

U.S. Department of Commerce Issues Proposed Rule Impacting AI and U.S. IaaS Providers to Counter Foreign Malicious Actors

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On January 29, 2024, the Bureau of Industry and Security (BIS) at the U.S. Department of Commerce issued a new proposed regulatory rule (the “Proposed Rule”), which will impose significant diligence, monitoring, and reporting...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

Dorsey & Whitney LLP

FinCEN Proposes AML Compliance Obligations for Non-Financed Real Estate Transactions

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Following consideration of comments received from an Advanced Notice of Proposed Rulemaking, on February 16, 2024, FinCEN issued a proposed rule (the “Proposed Rule”) that for the first time would require non-financed...more

Falcon Rappaport & Berkman LLP

FinCEN’s Anti-Money Laundering Regulations for Residential Real Estate Transfers

To crack down on money-laundering in the U.S. residential real estate market, the Financial Crimes Enforcement Network (“FinCEN”) has proposed new reporting requirements for certain real estate transactions. Specifically, the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Know Your Cloud Customer: Commerce Department Proposes To Regulate Foreign Access to US IaaS Products

On January 29, 2024, the Department of Commerce, Bureau of Industry and Security (BIS) released a proposed rule (Proposed Rule) that would require U.S. cloud services providers (a.k.a. Infrastructure as a Service, or IaaS,...more

Holland & Knight LLP

2023 PFAS Year in Review: EPA Policy and Aqueous Film-Forming Foam Litigation Updates

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2023 was a busy year for folks following legal developments related to per- and polyfluoroalkyl substances (PFAS). In December, the U.S. Environmental Protection Agency (EPA) issued its Second Annual Progress Report. Some of...more

Perkins Coie

Preparing for the 2024 Public Company Reporting Season

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In anticipation of the upcoming reporting season, this Update highlights some of the most significant rule changes, guidance, institutional investor areas of focus, and trends for public companies to consider in preparing...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - November 2023

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

Eversheds Sutherland (US) LLP

FinCEN proposes new recordkeeping and reporting rule for convertible virtual currency mixing

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

Foley Hoag LLP

Corporate Transparency Act Update: FinCEN Proposes Extending CTA Reporting Deadline for Companies First Created/Registered in 2024

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On September 27, 2023, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) to extend the deadline — from 30 days to 90 days — for domestic and foreign...more

Jenner & Block

SEC Adopts Rules on Cybersecurity Risk Management, Strategy, Governance and Incident Disclosure by Public Companies

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On July 25, 2023, the US Securities and Exchange Commission (the SEC), by a 3-2 vote, adopted final rules regarding cybersecurity risk management, strategy, governance and incident reporting by public companies (the Final...more

Perkins Coie

CISA Seeks Input on New Cybersecurity Reporting Requirements

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President Biden signed into law the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA) on March 15, 2022. The background and contours of CIRCIA are discussed in a previous update. CIRCIA authorizes and...more

Mitratech Holdings, Inc

The Impact of SEC’s Proposed New Rules in Cyber Risk Management

A new discourse in the cyber risk management landscape of US public companies is here. This past March 2022, the US Securities and Exchange Commission (SEC) added another item to their to-do list by announcing a...more

Perkins Coie

SEC Proposes New Cybersecurity Disclosure Rules on Incident Reporting, Risk Management, Strategy, and Governance

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As cybersecurity threats to the private and public sectors increase, the government has continued its efforts to enhance cybersecurity outside of government-controlled systems. On March 9, 2022, the U.S. Securities and...more

Fisher Phillips

Increase in Cyber-Attacks Leads to Influx of New Reporting Obligations

Fisher Phillips on

In the wake of Russia’s invasion of Ukraine, and amid growing concerns regarding the threat of increased cyberattacks targeting infrastructure and other critical industries, there has been a flurry of federal activity to...more

Sheppard Mullin Richter & Hampton LLP

Cybersecurity Act Signed Into Law Creates New Reporting Obligations

President Biden recently signed into law the Cyber Incident Reporting for Critical Infrastructure Act of 2022 as a part of a larger omnibus appropriations bill.  The new law sets out mandatory reporting requirements for...more

Cooley LLP

SEC votes to propose new rules for cybersecurity disclosure and incident reporting

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In remarks in January before the Northwestern Pritzker School of Law’s Annual Securities Regulation Institute, SEC Chair Gary Gensler addressed cybersecurity under the securities laws. (See this PubCo post.) Gensler suggested...more

Perkins Coie

SEC Proposes New Cybersecurity Risk Management Regime for Registered Funds and Advisers

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In today’s asset management landscape, cybersecurity threats are omnipresent, and with constantly evolving tools of attack, actual breaches have become increasingly prevalent. As the complexity, scope, and frequency of cyber...more

Holland & Knight LLP

SEC Proposes Substantial New Cybersecurity Requirements for Investment Advisers and Companies

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Following U.S. Securities and Exchange Commission (SEC) Chairman Gary Gensler's recent speech directing the agency to expand cybersecurity requirements on regulated entities, the SEC on Feb. 9, 2022, voted to propose new...more

Faegre Drinker Biddle & Reath LLP

SEC Proposes New Cybersecurity Risk Management Rules for Registered Investment Advisers and Funds

On Wednesday, the Securities and Exchange Commission announced proposed new cybersecurity risk management rules and amendments for investment advisers and investment companies. The proposed rules are designed to address...more

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