News & Analysis as of

Reporting Requirements Final Rules Enforcement Actions

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...more

Sheppard Mullin Richter & Hampton LLP

CFPB Halts Enforcement of Small Business Lending Rule for Institutions Outside Fifth Circuit

On April 30, the CFPB announced it will deprioritize enforcement and supervision of its small business lending data collection rule for institutions not covered by the stay issued by the U.S. Court of Appeals for the Fifth...more

DLA Piper

US: Department of Justice Issues Final Rule Restricting the Transfer of Sensitive Personal Data and United States...

DLA Piper on

On April, 8 2025, the Department of Justice’s final rule, implementing the Biden-era Executive Order 14117 restricting the transfer of Americans’ Sensitive Personal Data and United States Government-Related Data to countries...more

Thomas Fox - Compliance Evangelist

FCPA Compliance Report: Death of CTA

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode, Tom welcomes back Corporate Transparency Act expert and maven Jonathan Wilson for a look at how the Trump...more

Holland & Hart LLP

FinCEN EXEMPTS U.S. Companies and U.S. Persons from CTA Reporting Requirements

Holland & Hart LLP on

The Corporate Transparency Act (together with its implementing regulations, the CTA) is a federal law that went into effect on January 1, 2024. The CTA is aimed at combating financial crimes such as money laundering,...more

Morrison & Foerster LLP

The New CTA: Calling Foreign Reporting Companies Only

Since early December of last year, the CTA has been in a state of flux. As we recently reported, FinCEN announced it would delay the reporting deadline for most companies to March 21, 2025, and that it would provide any...more

Gibney Anthony & Flaherty, LLP

New Regulation on Alien Registration Requirement Takes Effect April 11

The U.S. Department of Homeland Security (DHS) has published an Interim Final Rule (IFR) requiring non-citizens who remain in the U.S. for 30 days or more and were not previously registered to register and be fingerprinted. ...more

Mintz - Energy & Sustainability Viewpoints

Sustainable Energy & Infrastructure CTA Updates — March 2025

FinCEN announced on February 27, 2025, that it will not impose fines or penalties for failures to file or update beneficial ownership information (BOI) reports in connection with the Corporate Transparency Act by the current...more

Maynard Nexsen

Department of Treasury Announces Halt in Enforcement of the CTA Against U.S. Citizens and Reporting Companies

Maynard Nexsen on

The past week has seen two major announcements that have significant implications on the Corporate Transparency Act (CTA). First, on February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will...more

Lowenstein Sandler LLP

FinCEN Announces No Fines or Penalties Under the CTA Pending New Rulemaking, New Narrowed Enforcement Scope

As discussed in our prior client alert, following the February 18 decision by the U.S. District Court for the Eastern District of Texas in Smith v. U.S. Dep’t of Treasury to stay a nationwide injunction it previously entered...more

Moritt Hock & Hamroff LLP

The Treasury Department Announces Suspension Of Enforcement Of Corporate Transparency Act Against U.S. Citizens & Domestic...

In a significant development, on March 2, 2025, the U.S. Department of the Treasury (the “Treasury Department”) announced that, not only will the Treasury Department not enforce any penalties or fines associated with the...more

Vorys, Sater, Seymour and Pease LLP

Corporate Transparency Act Deadlines Extended

On February 27, 2025, the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a release announcing that it intends to issue an interim final rule by March 21, 2025 that will extend the current deadlines to file or...more

Buckingham, Doolittle & Burroughs, LLC

FinCEN Temporarily Pauses Enforcement of Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act

On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not impose fines, penalties, or other enforcement actions against companies for failing to file or update beneficial ownership...more

Cozen O'Connor

FinCEN Pauses Enforcement Actions under CTA

Cozen O'Connor on

On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not take enforcement actions against any companies for failure to file or update beneficial ownership information (BOI) reports...more

Foley & Lardner LLP

FinCEN Not Issuing Fines or Penalties in Connection with Beneficial Ownership Information Reporting Deadlines for Now

Foley & Lardner LLP on

FinCEN announced that it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership information (BOI) reports pursuant to the...more

Proskauer Rose LLP

Corporate Transparency Act Deadlines on Hold

Proskauer Rose LLP on

On February 27, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced that it would not issue any fines or penalties or take other enforcement actions for a failure to comply...more

Neal, Gerber & Eisenberg LLP

Corporate Transparency Act is Again on Hold

On February 27, 2025, FinCEN announced “that it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership information (BOI)...more

McGlinchey Stafford

FinCEN Announces No Penalties for BOI Reporting Failures

McGlinchey Stafford on

On February 27, 2025, FinCEN announced “it will not issue any fines or penalties or take any other enforcement actions against companies based on any failure to file or update beneficial ownership information (BOI) reports...more

BakerHostetler

CTA Back in Effect; New Reporting Deadline of March 21

BakerHostetler on

On Feb. 17, the Texas federal district court in Smith v. U.S. Department of the Treasury granted the government’s motion for an immediate stay pending appeal of the nationwide order staying the effective date of the final...more

Orrick, Herrington & Sutcliffe LLP

Court stays a medical debt credit reporting case against CFPB

On February 13, the U.S. District Court for the Southern District of Texas stayed a lawsuit against the CFPB regarding the CFPB’s medical debt reporting final rule. The final rule, which the CFPB finalized in early January,...more

Morrison & Foerster LLP - Class Dismissed

EPA’s PFAS Enforcement Plan Advances As Two PFAS Reporting Requirements Set To Go Into Effect

EPA Adds Nine New PFAS to List of Chemicals Subject to Toxic Chemical Release Reporting Under the Emergency Planning and Community Right-to-Know Act and The Pollution Prevention Act On January 6, 2025, the EPA published a...more

McGlinchey Stafford

FinCEN Commits to Extend CTA Reporting for 30 Days If Court Grants Stay of Injunction

McGlinchey Stafford on

On February 5, 2025, the United States filed a motion in the case of Samantha Smith, et al., v. United States Department of Treasury, et al., to stay the order of the Federal District Court for the Eastern District of Texas,...more

Mayer Brown Free Writings + Perspectives

ICI Urges SEC to Delay Short-Sell Reporting Rules Amid Compliance Uncertainty

The Investment Company Institute (ICI) has asked the Securities and Exchange Commission (SEC) in a comment letter to delay enforcement of its new short sale disclosure rules (the “Short Sale Final Rules”) until additional...more

Hudson Cook, LLP

CFPB Bites of the Month - 2024 Annual Review - Auto

Hudson Cook, LLP on

In this article, we share a timeline of our monthly "bites" for 2024 applicable to the auto finance industry....more

Wiley Rein LLP

FCC Strengthens RMD Filing Requirements and Enforcement Capability

Wiley Rein LLP on

On January 8, 2025, the Federal Communications Commission (FCC or Commission) released a Report and Order (Order) adopting new rules for Robocall Mitigation Database (RMD) filings. Adopted unanimously by the Commission, the...more

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