News & Analysis as of

Reporting Requirements Compliance Enforcement Actions

K&L Gates LLP

Key Compliance Tips on How to Respond to Information Requests From OFSI

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On 8 May 2025, the United Kingdom’s Office of Financial Sanctions Implementation (OFSI) of HM Treasury published a penalty notice regarding a breach of financial sanctions by a UK registered company—Svarog Shipping & Trading...more

Venable LLP

Government Issues Nonenforcement Statement on Mental Health Parity Rules

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The government recently stated that it will delay enforcement of the 2024 final rules on the Mental Health Parity and Addiction Equity Act (MHPAEA). (Our previous alert regarding the 2024 final rules can be found here.) This...more

Skadden, Arps, Slate, Meagher & Flom LLP

OFSI Issues First-Ever Monetary Penalty for a Failure To Provide Information: Key Considerations for Companies

The Offence and Penalty - On 8 May 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) published its 11 April 2025 notice of its first-ever monetary penalty for an information offence relating to financial...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: Tennessee Division of Solid Waste Management Proposed Order and Assessment Addressing Ripley...

The Tennessee Division of Solid Waste Management (“TDSWM”) issued a February 7th Proposed Director’s Order and Assessment (“Order”) to SRG Global Coatings, LLC (“SRG”). See Case No. HWM 24-0024. The Order provides that...more

Eversheds Sutherland (US) LLP

Navigating new compliance requirements for DOJ’s Bulk Data Rule

While the US federal government is largely scaling back its rulemaking and compliance efforts, one critical exception is where personal data and technology intersect with national security. Exemplifying this trend, on April...more

Davis Wright Tremaine LLP

CFTC Divisions Issue Staff Advisory on Referrals to Division of Enforcement

On April 17, 2025, the Market Participants Division, the Division of Clearing and Risk, and the Division of Market Oversight (collectively, the "Operating Divisions") of the CFTC, along with the Division of Enforcement...more

Akin Gump Strauss Hauer & Feld LLP

OFSI Imposes Monetary Penalty Against Former Moscow Office of International Law Firm for Sanctions Breaches

On March 20, 2025, the U.K.’s Office of Financial Sanctions Implementation (OFSI) announced that, in accordance with section 146 of the Policing and Crime Act 2017 (PACA), a monetary penalty of £465,000 had been imposed...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Springdale Baking Facility...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“DEQ”) and Newly Weds Foods, LLC (“NWF”) entered into a March 25th Consent Administrative Order (“CAO”) addressing and alleged violation...more

DarrowEverett LLP

Private Placements in South Carolina: A Primer on Federal and State Securities Registration

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With an estimated 34 people moving to the Charleston area each day and with South Carolina claiming one of the fastest-growing populations in the nation last year , the post-COVID increase in the number of private placement...more

Morris, Manning & Martin, LLP

"Custody" for Registered Investment Advisers in Unusual Circumstances

For most registered investment advisers (RIAs), their annual update to Form ADV will be due on March 31, 2025. We have received several questions about “custody” and peculiar situations where RIAs may inadvertently have...more

Akin Gump Strauss Hauer & Feld LLP

Preserving and Protecting the Integrity of American Elections (Trump EO Tracker)

Enforce the Federal prohibition on foreign nationals voting in Federal elections. Requires documentary proof of United States citizenship and for verification from a State or local official for national mail voter...more

Pillsbury - CommLawCenter

Annual EEO Public File Report Deadline for Stations in Delaware, Indiana, Kentucky, Pennsylvania, Tennessee, and Texas

April 1 is the deadline for broadcast stations licensed to communities in Delaware, Indiana, Kentucky, Pennsylvania, Tennessee, and Texas to place their Annual EEO Public File Report in their Public Inspection File and post...more

Husch Blackwell LLP

Acting CFTC Chairman Caroline D. Pham Releases Additional Enforcement Guidance

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On March 11, acting Commodity Futures Trading Commission (CFTC) Chairman Caroline D. Pham offered insight into the regulator’s February 25, 2025 advisory in a keynote addressed delivered at Boca, the annual International...more

Segal McCambridge

Key Updates to the USEF Yellow Card System Taking Effect April 1, 2025

Segal McCambridge on

The United States Equestrian Federation (“USEF”) is the national governing body for equestrian sports in the United States. USEF sets forth rules and regulations for its membership which includes owners, trainers, and amateur...more

Otten Johnson Robinson Neff + Ragonetti PC

A Continuing Saga of CTA Uncertainty

On February 27, 2025, FinCEN published guidance related to the Corporate Transparency Act (the “CTA”) taking the position that it would not “issue any fines or penalties or take any other enforcement actions against any...more

DLA Piper

SEC Permits Rule 506(c) Accredited Investor Verification with Self-Certification

DLA Piper on

The US Securities and Exchange Commission (SEC) has published no-action guidance providing clarity to issuers relying on Rule 506(c) of Regulation D – an exempt offering pathway that permits issuers to publicly advertise an...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Missouri Department of Natural Resources and St. Charles Retail Motor Fuel Facility Enter into Administrative...

The Missouri Department of Natural Resources (“MDNR”) and Mac’s Convenience Stores LLC (“Mac’s”) entered into a February 26th Administrative Order on Consent (“AOC”) addressing an alleged violation of the Missouri Air...more

White & Case LLP

US Supreme Court Rejects Application of Commingling Theory in Holocaust Expropriation Case

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On February 21, 2025, the US Supreme Court issued a unanimous decision in Republic of Hungary v. Simon, further narrowing the scope of the Foreign Sovereign Immunities Act's exception to sovereign immunity for expropriation...more

Ward and Smith, P.A.

Corporate Transparency Act Enforcement Suspended Once Again!

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In a press release, Treasury officials confirmed they would not impose fines on U.S. citizens or domestic reporting companies, effectively pausing the reporting obligations for the time being.  Under the original CTA...more

Buchalter

FinCEN Lowers Reporting Threshold for MSBs Near U.S.-Mexico Border to Combat Money Laundering

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On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) operating within 30 specified ZIP codes near the U.S.-Mexico border...more

Dickinson Wright

April 11, 2025 Registration Rule Enhanced: Foreign Nationals – Carry Your Papers!

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On March 11, the U.S. Department of Homeland Security (DHS) published the draft of its proposed new registration Interim Final Regulation (IFR) referenced in the announcement by U.S. Citizenship and Immigration Services...more

Nilan Johnson Lewis PA

Pay Data Reporting – Off the Hook or Temporary Reprieve?

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In 2016, the EEOC announced big changes to EEO-1 reporting. The new initiative, led by Obama-era appointees, required employers to report an entirely new category of data covering pay and hours worked for the purpose of...more

Mayer Brown

CFTC’s Division of Enforcement Issues New Advisory on Self-Reporting, Cooperation and Remediation

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AT A GLANCE - New guidance on self-reporting, cooperation, and remediation was recently released by the Commodity Futures Trading Commission’s Division of Enforcement (CFTC). The CFTC’s advisory includes tiered scales for...more

Warner Norcross + Judd

CTA Filing is Now Voluntary for US Entities and Citizens: Rule Changes Ahead

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The United States Treasury Department announced on March 2, 2025, that the Beneficial Ownership Information (BOI) reporting required by the Corporate Transparency Act (CTA) is now voluntary for U.S. entities and citizens....more

Holland & Hart LLP

The CTA Is Back (Sort Of)—What Reporting Companies Need to Know

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After months of litigation—including a cameo before the Supreme Court—the last nationwide injunction of the Corporate Transparency Act (CTA) was vacated and the CTA was set to go back into effect. Since then, nothing has been...more

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