News & Analysis as of

Reporting Requirements Department of Justice (DOJ) Enforcement

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

Perkins Coie

DOJ’s Bulk Personal Data Rule Becomes Effective–Resources for Compliance

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The new Department of Justice (DOJ) rule governing international transfers of Americans’ information, codified at 28 C.F.R. Part 202, became effective on April 8, 2025....more

The Volkov Law Group

DSP Compliance: DOJ Sets July 8, 2025 Deadline (Part III of III)

The Volkov Law Group on

As if legal and compliance professionals had enough responsibilities on their plates, DOJ dropped another shoe (to join the tariffs, sanctions and export controls, and immigration issues) and upped the stakes for ethics and...more

Fox Rothschild LLP

Corporate Transparency Act Back in Effect: March 21 Is the New Deadline to File Beneficial Ownership Reports

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The Corporate Transparency Act’s (CTA) reporting requirements are officially back in force, requiring non-exempt entities to disclose beneficial ownership information (BOI). This week, a Texas federal court lifted the last...more

Paul Hastings LLP

DOJ Announces Significant Proposed Changes to Amend and Clarify FARA

Paul Hastings LLP on

On December 19, 2024, the Department of Justice (DOJ) published a Notice of Proposed Rulemaking (NPRM) intended to “update and clarify” the regulations under the Foreign Agents Registration Act (FARA). The proposed changes to...more

Proskauer - Health Care Law Brief

CMS Publishes Final Rule, Effective January 1, 2025, Addressing the Requirements for Reporting and Returning Overpayments

The standard for an “identified overpayment” under Medicare Parts A–D now aligns with section 1128J(d)(4)(A) of the Social Security Act, which incorporates by reference the Federal False Claim Act’s (the “FCA”) “knowledge”...more

Wiley Rein LLP

CTA Update: Supreme Court Temporarily Lifts Injunction, but Requirements Remain Blocked

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On January 23, 2025, the U.S. Supreme Court issued a ruling that appears to settle – for now – a nearly two-month-long legal battle over the Corporate Transparency Act (CTA), which began with a nationwide preliminary...more

McGuireWoods LLP

U. S. Supreme Court Vacates National Injunction Staying the CTA in One Case, But a Separate Nationwide Stay Against Enforcement...

McGuireWoods LLP on

Here we go again – another CTA update hot off the press. In our last update, we reported that the U.S. Department of Justice (DOJ) filed with the U.S. Supreme Court an emergency application to stay the injunction...more

Amundsen Davis LLC

U.S. Supreme Court Provisionally Reinstates the Corporate Transparency Act

Amundsen Davis LLC on

The U.S. Supreme Court issued an order on January 23, 2025, which provisionally reinstates the Corporate Transparency Act (CTA) while a legal challenge to it continues. This brief order, which stayed an injunction against the...more

Perkins Coie

2025 Updates to HSR and Interlocking Directorate Thresholds

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The Federal Trade Commission (FTC) recently announced its annual adjustments to (1) the pre-merger notification thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (the HSR Act), (2) the HSR Act filing...more

Farella Braun + Martel LLP

What’s Ahead as Corporate Transparency Act Comes to a Crossroads

The recent whiplash regarding the validity of the Corporate Transparency Act (CTA)—it was enjoined just to particular parties, then enjoined nationwide, then un-enjoined, then enjoined again, while other courts let it...more

Hinch Newman LLP

DOJ Issues Rule Addressing Threat Posed by Foreign Adversaries’ Access to Americans’ Sensitive Personal Data

Hinch Newman LLP on

On Friday, December 27, 2024, the Justice Department issued a final rule to address “urgent national security risks posed by access to U.S. sensitive personal and government-related data from countries of concern and covered...more

Davis Wright Tremaine LLP

UPDATE : 5th Circuit Reinstates Injunction Pausing Enforcement of the Corporate Transparency Act

After a preliminary injunction temporarily halted the enforcement of the Corporate Transparency Act ahead of its January 1, 2025 reporting deadline for companies formed prior to 2024, the Fifth Circuit has lifted the...more

Rothwell, Figg, Ernst & Manbeck, P.C.

Update: The Corporate Transparency Act Put On Hold

As an update to our post on the Corporate Transparency Act, on December 3, 2024, a federal district court issued a nationwide preliminary injunction pertaining to the Corporate Transparency Act in Texas Top Cop Shop, Inc. v....more

Best Best & Krieger LLP

Texas Federal Court Blocks Enforcement of Corporate Transparency Act

Best Best & Krieger LLP on

On Tuesday December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction which precludes enforcement of the Corporate Transparency Act (CTA) (See, Texas Top Cop Shop,...more

McNees Wallace & Nurick LLC

Corporate Transparency Act Dealt Blow by Eastern District of Texas: How Reporting Companies Can Proceed

On Tuesday, December 3, 2024, the Federal District Court for the Eastern District of Texas (the “Court”) issued an opinion in Texas Top Cop Shop, Inc. et al. v. Merrick Garland, Attorney General of the United States, et al....more

White and Williams LLP

Federal Court Suspends Enforcement of the Corporate Transparency Act’s Reporting Requirements

White and Williams LLP on

On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a preliminary injunction prohibiting the federal government from enforcing the Corporate Transparency Act (the “CTA”) nationwide. Texas Top...more

Pierce Atwood LLP

Federal Government Appeals Suspension of Corporate Transparency Act Deadline

Pierce Atwood LLP on

On December 3, 2024, the Eastern District of Texas issued a nationwide preliminary injunction suspending enforcement of the Corporate Transparency Act (CTA), less than a month before the deadline. The ruling temporarily...more

Greenberg Glusker LLP

Nationwide Injunction Halts Enforcement of the Corporate Transparency Act

Greenberg Glusker LLP on

UPDATE as of 12/7/2024: FinCen has updated their website addressing the recent federal court order, publicly stating that reporting companies are not currently required to file beneficial ownership information with FinCEN and...more

Flaster Greenberg PC

Preliminary Injunction Blocking Enforcement of the Corporate Transparency Act

Flaster Greenberg PC on

We previously discussed a ruling by a federal District Court in Alabama finding that the Corporate Transparency Act (“CTA”) was unconstitutional, with the holding limited to the plaintiffs in the case. For general background...more

King & Spalding

Federal District Court in Texas Grants “Nationwide” Preliminary Injunction Against CTA Enforcement

King & Spalding on

On December 3, 2024, the United States District Court for the Eastern District of Texas entered a nationwide preliminary injunction against the enforcement of the Corporate Transparency Act (“CTA”) and its implementing...more

Farella Braun + Martel LLP

Nationwide Injunction Halts Corporate Transparency Act Enforcement

A recent federal court decision eliminates the present need for any person or company to comply with the Corporate Transparency Act (CTA) and its implementing regulations. This decision may be reversed upon appeal, but as of...more

Akin Gump Strauss Hauer & Feld LLP

Federal Court Issues Preliminary Injunction of CTA

On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a preliminary injunction regarding enforcement of the Corporate Transparency Act (CTA) and related beneficial ownership reporting rule. The...more

Adams & Reese

“Christmas Curveball” – CTA Temporarily Blocked Nationwide by Texas Court Injunction

Adams & Reese on

A Texas federal court judge has thrown a Christmas curveball at FinCEN with less than one month remaining before the CTA deadline of Jan. 1, 2025. On that date more than 30 million companies would be required to report their...more

Holland & Hart LLP

What Does the Nationwide Preliminary Injunction of the Corporate Transparency Act Mean for Businesses?

Holland & Hart LLP on

On December 3, 2024, the U.S. District Court for the Eastern District of Texas granted a nationwide preliminary injunction barring enforcement of the Corporate Transparency Act (CTA)1 and its key implementing regulations...more

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