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Rulemaking Process Enforcement Actions Compliance

Jackson Lewis P.C.

USCIS Issues Regulation Requiring Alien Registration

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On March 12, 2025, USCIS issued an Interim Final Regulation (IFR) designating a new registration form to comply with statutory alien registration and fingerprinting provisions. The IFR goes into effect on April 11, 2025....more

Bracewell LLP

Another CTA Freeze: Treasury Department Announces Suspension of Enforcement Against Domestic Reporting Companies

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If you have been following our reports on the subject, you know that the Corporate Transparency Act (CTA) had a tumultuous end to 2024 and start to 2025, with a series of court actions leading to oscillating reports about...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

Downs Rachlin Martin PLLC

Corporate Transparency Act – U.S. Treasury Department Suspends Enforcement Against U.S. Citizens and Domestic Reporting Companies

The fate of the Corporate Transparency Act (CTA) has been anything but certain since the beneficial ownership information (BOI) reporting rule took effect in January 2024. While several legal challenges to the CTA make their...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

Whiteford

Client Alert: CTA Enforcement Suspended – Key Updates on Filing Requirements

Whiteford on

On March 2, 2025, the U.S. Department of the Treasury t (“Treasury”) announced that it will not impose penalties, fines, or pursue enforcement actions against U.S. companies, citizens, or their beneficial owners for failing...more

Foley & Lardner LLP

Treasury Department Announces Suspension of Enforcement of Corporate Transparency Act Against U.S. Citizens and Domestic Reporting...

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The Treasury Department announced plans to significantly narrow beneficial ownership information (BOI) reporting obligations under the Corporate Transparency Act (CTA)....more

Perkins Coie

Corporate Transparency Act: Treasury Announces No Enforcement for Reporting Failures by U.S. Citizens and Domestic Reporting...

Perkins Coie on

Last week, we reported that the Financial Crimes Enforcement Network (FinCEN) reinstated the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements, with a new deadline for most...more

Husch Blackwell LLP

U.S. Treasury Department Declines to Enforce CTA

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On March 2, 2025, the U.S. Department of the Treasury ended months of speculation regarding how the Corporate Transparency Act (CTA) would be implemented and enforced under the second Trump administration. Via press release,...more

Snell & Wilmer

The Corporate Transparency Act Update: A Reprieve for American Businesses?

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In another twist as to the future of the Corporate Transparency Act’s (CTA) implementation and judicial intervention, on February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not be...more

Pierce Atwood LLP

Out With a Bang: Treasury Restricts Corporate Transparency Act to Foreign Reporting Companies

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On March 2, 2025, the Treasury Department announced suspension of the March 21, 2025 deadline for filing under the Corporate Transparency Act (CTA) for any domestic companies or U.S. citizens....more

Shipkevich PLLC

U.S. Treasury Department Announces Suspension of BOI Reporting Penalties for U.S. Parties

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On February 19, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced that most reporting companies under the Corporate Transparency Act (“CTA”) must now submit their Beneficial Ownership Information (“BOI”)...more

Husch Blackwell LLP

Eastern District of Kentucky Tolls Compliance Deadlines for § 1033 of the Dodd-Frank Act

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On February 25, 2025, Judge Danny C. Reeves of the Eastern District of Kentucky granted a Joint Motion to Stay Proceedings in Forcht Bank, NA et al v. Consumer Financial Protection Bureau et al, temporarily staying litigation...more

Davis Wright Tremaine LLP

New Administration Outlook: What Does the CFPB "Freeze" Mean for Regulations and Pending Litigation?

Treasury Secretary Scott Bessent, who is currently serving as the acting director of the Consumer Financial Protection Bureau (CFPB), emailed staff on Monday directing employees to cease all rulemaking activities and delay...more

Davis Wright Tremaine LLP

New Administration Outlook: A Possible Roadmap to What's Ahead for the CFTC Under New Leadership

On January 20, 2025, the Commodity Futures Trading Commission ("CFTC") unanimously elected Commissioner Caroline D. Pham as acting chairman. The Administration has not yet identified who will be nominated for the position of...more

Morrison & Foerster LLP

Extended Compliance Date for Recent Form PF Amendments

The new year always marks the start of a busy regulatory filing season for registered investment advisers, including investment advisers that file Form PF (“Form PF Filers”). This year could be especially challenging since,...more

Paul Hastings LLP

SEC Reportedly Requiring Enforcement Staff to Seek Commission Approval for Formal Orders of Investigation

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On February 2, media outlets reported that the Securities and Exchange Commission (SEC or Commission) has told SEC Enforcement attorneys that they need the approval of the agency’s commissioners for all formal orders of...more

Sheppard Mullin Richter & Hampton LLP

Fifth Circuit Strikes Down FTC’s ‘Junk Fee’ Rule for Auto Dealers

On January 24, 2025, the Fifth Circuit Court of Appeals struck down an FTC rule aimed at curbing deceptive advertising and sales practices in the auto industry. The rule, which sought to prohibit certain “junk fees” and...more

Hinch Newman LLP

FCC Postpones Effective Date of TCPA One-to-One Consent Rule Before it is Vacated by the Eleventh Circuit

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On the eve prior to its effective date, the FCC’s One-to-One Consent Rule that sought to redefine the meaning of "prior express written consent" under the Telephone Consumer Protection Act, was postponed for one year by order...more

Akin Gump Strauss Hauer & Feld LLP

“Under the Wire” E-Comms Settlements: More Confusion Than Closure

On January 13, 2025, the U.S. Securities and Exchange Commission announced settled enforcement actions with five registered investment advisers for failing to maintain and preserve internal electronic communications. These...more

Husch Blackwell LLP

MSHA/OSHA Civil Penalty Amounts Increase for 2025

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On January 10, 2025, the Department of Labor’s annual penalty adjustments were published in the Federal Register. The 2025 increases are approximately 2.6%.  The chart below applies to any penalties assessed after January 15,...more

Husch Blackwell LLP

California’s Proposition 65 Short-Form Warnings Now in Effect

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California’s Office of Environmental Health Hazard Assessment (OEHHA) issued a notice of proposed amendments to Proposition 65 in October 2023 that significantly modify the information businesses are required to provide in...more

Husch Blackwell LLP

CBP Proposes Changes to the De Minimis Entry Process

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U.S. Customs and Border Protection (CBP) issued a Notice of Proposed Rulemaking on January 13, 2025, regarding an update to the rules governing de minimis shipments. The public can make comments on the proposed rule until...more

Morrison & Foerster LLP

The FTC’s Final “Click-to-Cancel” Rule Faces Legal and Political Hurdles

The fate of the FTC’s long-awaited final “Click-to-Cancel” rule has become tangled in uncertainty as it faces numerous lawsuits and the new incoming presidential administration. In October, the FTC published its Final Rule...more

Katten Muchin Rosenman LLP

The SEC Lives On Under New Leadership — What to Expect

President-elect Donald J. Trump nominated Paul Atkins to succeed Gary Gensler as Securities and Exchange Commission (SEC or Commission) Chair on December 4. Atkins was an SEC staff attorney under SEC Chairs Richard Breeden...more

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