News & Analysis as of

Reporting Requirements National Security Compliance

Guidepost Solutions LLC

Unlocking Opportunity: Navigating the New Data Center Validated End User Program

Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a significant interim final rule (IFR) that has created both challenges and exciting opportunities for these operators. This IFR...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

Paul Hastings LLP

The UK Launches Its Own ‘FARA’: What Companies Need to Know About the New Foreign Influence Registration Scheme

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On July 1, 2025, the United Kingdom’s new Foreign Influence Registration Scheme (FIRS) will formally take effect, creating sweeping registration obligations under U.K. law for persons engaging in certain activities on behalf...more

Wiley Rein LLP

New DOJ Restrictions on Cross-Border Data Transactions Take Effect April 8: Ten Questions as Your Business Prepares to Comply

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The U.S. Department of Justice’s (DOJ) sweeping new rule on cross-border data transactions is set to take effect in substantial part next month, with broad implications for companies that transfer U.S. personal data or...more

Verrill

NEED MORE COWBELL: FinCEN Not Satisfied with Current Deadlines and Requirements under the Corporate Transparency Act

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On February 27, 2025, FinCEN issued a press release announcing future changes but giving no guidance about the scope of those changes: “No later than March 21, 2025, FinCEN intends to issue an interim final rule that...more

Foley Hoag LLP

Corporate Transparency Act Revived After Last Remaining Nationwide Preliminary Injunction is Lifted - Reporting Deadlines Extended

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On February 18, 2025, the U.S. Federal District Court for the Eastern District of Texas lifted the last remaining nationwide preliminary injunction of the CTA in the Smith case. This follows a decision on January 23, 2025, by...more

Amundsen Davis LLC

The Corporate Transparency Act Is Back in Effect With a March 21 Reporting Deadline

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced in a February 19, 2025 alert that the Corporate Transparency Act (CTA) is back in effect. The new deadline for most companies to...more

Nelson Mullins Riley & Scarborough LLP

Corporate Transparency Act Reporting Obligations Reinstated; Deadline Extended 30 Days

On February 19, 2025, FinCEN released a statement that BOI reporting obligations under the CTA are back in effect, after a recent U.S. District Court decision in the ongoing case of Smith et al. v. U.S. Department of the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Now More Than Ever, Supply Chains Demand the Attention of Multinationals’ Boards

Key Points - - New laws in major jurisdictions make it vital that companies examine their supply chains closely for legal vulnerabilities. This entails due diligence on environmental and human rights issues, and compliance...more

McGlinchey Stafford

CTA’s Beneficial Ownership Reporting Requirement Resumes – At Least for Now

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As the saga of on-again-off-again requirements continues to unfold, FinCEN’s Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA) have undergone significant changes due to...more

Perkins Coie

DOJ’s Final Rule on Data Transfers: Impacts Across Industries

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As of January 23, 2025, the regulation discussed below has not been withdrawn by the Trump administration and is not subject to automatic withdrawal under President Trump’s Executive Order freezing regulations. It currently...more

American Conference Institute (ACI)

[Event] 9th Annual Canadian Forum on Global Economic Sanctions - February 26th - 27th, Toronto, ON, Canada

CI’s 9th Annual Canadian Forum on Global Economic Sanctions is designed to cover your top compliance challenges, offering unparalleled networking and benchmarking opportunities for economic sanctions, trade, financial crime,...more

PilieroMazza PLLC

FY2025 NDAA: Significant Impacts on Small and Large Defense Contractors

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The Servicemember Quality of Life Improvement and National Defense Authorization Act for Fiscal Year 2025 (FY2025 NDAA), signed into law on December 23, 2024, has significant implications for defense acquisition and...more

American Conference Institute (ACI)

[Event] Advanced Forum on Global Export Controls - February 25th - 26th, Arlington, VA

Looking for something more advanced than your average export controls conference? Go beyond the basics at ACI’s 2nd Annual Advanced Forum on Global Export Controls. This premier event offers cutting-edge insights and...more

Fox Rothschild LLP

Investments in Chinese Technology Companies Limited by New US Outbound Investment Rule

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U.S. investors interested in investing in advanced Chinese technology companies may now be constrained by the U.S. Government’s first-ever outbound investment rule (Final Rule) which took effect on Jan. 2, 2025. The Final...more

Sheppard Mullin Richter & Hampton LLP

Governmental Practice Cybersecurity and Data Protection: 2024 Recap & 2025 Forecast Alert

To kick off the New Year (and as is now tradition, since we put out a similar Recap & Forecast last year), Sheppard Mullin’s Governmental Practice Cybersecurity & Data Protection Team has prepared a cybersecurity-focused 2024...more

King & Spalding

DOJ Issues Final Rule Restricting Foreign Access to U.S. Data

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The rule imposes substantial new diligence, reporting, cybersecurity, and auditing obligations on companies. On December 27, 2024, the U.S. Department of Justice (“DOJ”) issued a final rule implementing Executive Order...more

Goodwin

Focus on FOCI: Expanded Reporting Requirements Arrive for Defense Contractors

Goodwin on

On May 13, 2024 the U.S. Department of Defense (DoD) published Instruction 5205.87: Mitigating Risks Related to Foreign Ownership, Control, or Influence for Covered DoD Contractors and Subcontractors (the Instruction), which...more

Davis Wright Tremaine LLP

FCC Proposes New Regulations To Assess and Protect Against National Security Risks in Submarine Cable Networks

On November 21, 2024, the Federal Communications Commission ("FCC") approved a Notice of Proposed Rulemaking ("NPRM") focused on enhancing FCC review and oversight of the global subsea communications cable network through...more

Latham & Watkins LLP

FCC Reviews Submarine Cable Rules to Address National Security and Law Enforcement Risks

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Potential rule changes could expand the scope of the disclosure and reporting obligations for applicants and licensees of submarine cables....more

American Conference Institute (ACI)

The Future of Plurilateral Agreements: Compliance Considerations

The evolution of critical and emerging technologies continues to affect how the United States and its international allies and partners uniformly protect against national security threats. For industry, the strengthening of...more

Latham & Watkins LLP

Final US Outbound Investment Rules to Be Effective January 2, 2025: Key Questions Answered

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The Final Rule prohibits or requires notification of certain US investments in Chinese and Chinese-controlled entities involved in semiconductors, quantum information technologies, and artificial intelligence....more

Lathrop GPM

Six-Step Quick Guide to the Beneficial Ownership Information (“BOI”) Reporting Rules of the Corporate Transparency Act (“CTA”)

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In September 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued the final beneficial ownership information (“BOI”) reporting rules (the “BOI Reporting Rules”) of the Corporate...more

Seward & Kissel LLP

Compliance Flash: OFAC Announces New Reporting Requirement for Financial Institutions Under the REPO for Ukrainians Act

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The supplemental appropriations legislation signed into law on April 24, 2024 enacted numerous high-profile provisions addressing aspects of U.S. foreign policy and national security, including provisions that broaden and...more

Eversheds Sutherland (US) LLP

The Corporate Transparency Act is unconstitutional - For some, and for now

On March 1, 2024, the United States District Court for the Northern District of Alabama found that the Corporate Transparency Act (CTA) is unconstitutional because it exceeds Congress’ legislative power. The 53-page opinion...more

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