News & Analysis as of

Reporting Requirements Enforcement

A&O Shearman

ESMA report on the quality and use of data

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The European Securities and Markets Authority (ESMA) has published its 2024 report, along with a press release, on the quality and use of data, showcasing significant increase in data use by authorities. The report covers...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

Hogan Lovells

UK Government updates guidance on modern slavery and supply chain transparency

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The UK Home Office has published an updated version of Transparency in Supply Chains (TISC), A Practical Guide which provides guidance on how organisations should “comply with the letter and spirit” of corporate reporting...more

Warner Norcross + Judd

PFAS Regulatory Landscape Continues to Shift: EPA Announces Major Actions and State PFAS Bans Grow

Last week the EPA announced a broad array of agency objectives regarding per‑ and polyfluoroalkyl substances (PFAS) regulation. Although the agency’s announcement was sparing on details, it provides a few key indicators...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

A&O Shearman

Pay Transparency – the Netherlands proposes new legislation

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The Directive 2023/970/EC (Directive) aims to strengthen the principle of equal pay for equal work between men and women through transparency and enforcement mechanisms. The Directive generally applies to all employers and...more

The Volkov Law Group

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

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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

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

Ropes & Gray LLP

New York State Publishes Proposed Facility- and Industry-Specific Greenhouse Gas Emissions Reporting Requirements

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At the end of March, the New York State Department of Environmental Conservation (DEC) released draft regulations for a proposed Mandatory Greenhouse Gas Reporting Program. If adopted, the regulations would require annual...more

Cadwalader, Wickersham & Taft LLP

Shifting Signals, April 2025 - Relief for Swap Dealer Pre-Trade Disclosures

On April 4, 2025, the staff of the Commodity Futures Trading Commission ("CFTC") Market Participants Division ("MPD") issued compliance relief for registered swap dealers ("SDs") from the requirement to provide the so-called...more

Snell & Wilmer

The (Almost) End of the Corporate Transparency Act

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In a whirlwind attempt to follow the roller coaster actions in the courts, the U.S. Congress, and FinCEN’s administrative efforts, Snell & Wilmer has worked to keep clients updated with the drama-filled developments of the...more

McNees Wallace & Nurick LLC

Closing Call for the Corporate Transparency Act: FinCEN Removes Reporting Requirements for Domestic Business Entities

After almost fifteen months of legal challenges, conflicting court rulings, changing guidance from the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN), and a general air of uncertainty, it appears...more

Seward & Kissel LLP

Update: U.S. Companies and U.S. Persons No Longer Required to Provide Beneficial Ownership Information under the Corporate...

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Following the Treasury Department’s announcement regarding the removal of fines and penalties under the Corporate Transparency Act (“CTA”), the Financial Crimes Enforcement Network (“FinCEN”) has now advised that U.S....more

Morgan Lewis

EU Pay Transparency Directive: The Current Status and How To Prepare

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EU member states have until 7 June 2026 to implement the EU Pay Transparency Directive (the Directive) into their domestic law. This LawFlash summarises the Directive’s key requirements, considers the current implementation...more

Chambliss, Bahner & Stophel, P.C.

Treasury Department Will Not Enforce Corporate Transparency Act Against U.S. Businesses

After months of uncertainty, legal challenges, and changing deadlines under the Corporate Transparency Act (CTA), the Treasury Department issued a press release on March 2, 2025, stating that it would not enforce any...more

Morgan Lewis

CFTC Enforcement Replaces Previous Cooperation Guidance With New Mitigation Credit Matrix

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The Division of Enforcement of the US Commodity Futures Trading Commission (CFTC or Commission) recently issued an advisory revoking prior guidance for its staff in recommending enforcement resolutions (the Advisory) and...more

Wilson Sonsini Goodrich & Rosati

U.S. Treasury Department Announces Changes to the BOI Reporting Requirements Under the Corporate Transparency Act

On March 2, 2025, the Department of Treasury confirmed in a press release that it will not enforce any penalties or fines associated with the BOI reporting requirements under the existing regulatory deadlines...more

Morris, Manning & Martin, LLP

FinCEN Announces Deadline Extension and Enforcement Pause

The ongoing saga of the Corporate Transparency Act (CTA) continues! On the evening of February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced three key developments. What Does This Mean for Your...more

Akin Gump Strauss Hauer & Feld LLP

Making America Healthy Again By Empowering Patients With Clear, Accurate, and Actionable Healthcare Pricing Information (Trump EO...

The EO announces a policy of the United States to put patients first and ensure they have the necessary information to make well-informed healthcare decisions. The order builds upon Executive Order 13877 (Improving Price and...more

Coblentz Patch Duffy & Bass

UPDATE – Mandatory BOI Reporting Requirements Reinstated; March 21, 2025 Due Date

In our last client alert about the Corporate Transparency Act (CTA), an injunction against enforcement of the CTA remained in effect. On February 17, 2025, the injunction was stayed, and there are currently no impediments to...more

Kohrman Jackson & Krantz LLP

The Corporate Transparency Act Returns: What You Need to Know

Beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect. In the latest in a line of dizzying decisions surrounding the CTA, in Smith v. U.S....more

Dickinson Wright

Texas Court Recognizes Supreme Court Ruling, Reinstates BOI Filing Requirement

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The Corporate Transparency Act (CTA or the Act) is back in play. In an Order released on Feb. 17, 2025, a federal district court in the Eastern District of Texas stayed its Order from Jan. 7, 2025, which had enjoined...more

Sheppard Mullin Richter & Hampton LLP

The Return of the CTA: FinCEN Confirms that Beneficial Ownership Information Reporting Requirements are Back in Effect with a New...

On February 19, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced that beneficial ownership information reporting requirements under the Corporate Transparency Act (“CTA”) are back in effect with a new...more

Perkins Coie

Corporate Transparency Act: FinCEN Reinstates Reporting Requirements with March 21 Deadline

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Earlier this week, the Financial Crimes Enforcement Network (FinCEN) issued a new notice confirming that the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements are back in effect....more

Whiteford

Client Alert: Mandatory CTA Compliance Returns – What You Need to Know

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On February 17, 2025, the U.S. District Court for the Eastern District of Texas lifted the last remaining nationwide injunction against enforcement of the Corporate Transparency Act (CTA) previously issued in Smith v. US...more

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