On August 29, 2024, the Financial Crimes Enforcement Network (“FinCEN”) published a final rule (the “Rule”) requiring reports by “reporting persons” concerning real estate transfers to a legal entity or trust of certain...more
As reported in our earlier QuickStudies on the Corporate Transparency Act (the “CTA”) and the Regulations adopted by the Financial Crimes Enforcement Network (“FinCEN”), each company in existence on or after January 1, 2024...more
On July 30, 2024, New York Attorney General Letitia James announced two new privacy guides that could affect your business, a Business Guide to Website Privacy Controls and a Consumer Guide to Web Tracking....more
On August 14, the Federal Trade Commission (the “FTC”), acting unanimously pursuant to its authority under Section 5 of the Federal Trade Commission Act, announced the adoption of a final Trade Regulation Rule on the Use of...more
On December 21, 2024, amendments to the New York Limited Liability Company Law will take effect requiring domestic New York LLCs and foreign LLCs qualified to do business in New York to disclose information concerning their...more
Public Companies are Exempt, But . . .
Public companies have an exemption from the filing requirements under the new Corporate Transparency Act (CTA) reporting rules. The public company exemption applies to companies that...more
As of January 1, 2024 (the “Effective Date”), many domestic and foreign entities formed or registered by a filing with a Secretary of State or comparable office in a State, the District of Columbia or a tribal authority (a...more
The Financial Crimes Enforcement Network (FinCEN), a part of the U.S. Treasury Department, amended the regulations under the Corporate Transparency Act (CTA) to extend the 30 day deadline to 90 days from the date of formation...more
On November 15, 2023, the FTC announced that it had issued fourteen Warning Letters to the two trade associations, the American Beverage Association (AmeriBev) and the Canadian Sugar Institute (“the Associations”), as well...more
The Corporate Transparency Act (“CTA”), which goes into effect on January 1, 2024, requires filings with the Financial Crimes Enforcement Network (“FinCEN”) (part of the U.S. Department of the Treasury) by most newly formed...more
FinCEN, a part of the U.S. Department of the Treasury, issued its Small Business Compliance Guide (the “Guide”) to assist companies and their managements and advisors to meet their filing requirements under the Corporate...more
For the first time since 2009, the Federal Trade Commission (“FTC”) released changes to the FTC’s Endorsement Guides, which advise advertisers, brand ambassadors and endorsers (collectively, “endorsers”) on what practices may...more
7/11/2023
/ Advertising ,
Corporate Counsel ,
Disclosure Requirements ,
Endorsements ,
Fake Reviews ,
Federal Trade Commission (FTC) ,
FTC Endorsement Guidelines ,
Influencers ,
Marketing ,
Online Endorsements ,
Social Media ,
Unfair or Deceptive Trade Practices
We are updating our March 6, 2023 QuickStudy that discussed the new statutory exemption under section 15(b)(13) of the Securities Exchange Act of 1934 from broker registration that allows unregistered M&A advisers to provide...more
On March 29, 2023, a new federal statutory exemption for M&A brokers takes effect by the addition of Section 15(b)(13) to the Securities Exchange Act of 1934 (the “Exchange Act”). The new provision exempts certain M&A brokers...more
Final regulations were adopted on September 29, 2022 by the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of Treasury (the “Beneficial Ownership Rule” or the “Rule”) under the Corporate Transparency...more
As a follow-up to our earlier QuickStudies on the Corporate Transparency Act (“CTA”), Anti-Money Laundering Act of 2020 ("AMLA") and art and antiquities under the AMLA, we are providing this QuickStudy to highlight a few...more
On December 7, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) under the Corporate Transparency Act (the “CTA”). The CTA went into effect January 2, 2020 and...more
On September 23, 2021, the Financial Crimes Enforcement Network (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) soliciting public comment on possible rules implementing Section 6110 of the Anti-Money...more
On July 1st, the Federal Trade Commission (FTC) issued a new rule to deter what the Commission characterized as “rampant fraud” in the use of Made in USA labels. The effective date of the new rule will be thirty days from...more
The Anti-Money Laundering Act of 2020 (the “AMLA”), which became law January 2, 2021 with Congress’ override of then President Trump’s veto of the Defense Appropriations Act of 2021 included provisions bringing dealers in...more
The House of Representatives and the Senate voted to override President Trump’s veto of the National Defense Authorization Act for Fiscal Year 2021 (“NDAA”). The NDAA includes the Anti-Money Laundering Act of 2020 (“AMLA”)...more
Through December 31, 2020, New York business corporations and New York Not for Profit corporations may hold virtual annual or special shareholder and member meetings through electronic means. Recognizing Governor Andrew...more
Recently, the U.S. District Court in the Southern District of New York held in Kirschner v. J.P. Morgan that a syndicated term loan was not a “security” under several state securities (or Blue Sky) laws. While the ruling did...more
This month, the Federal Trade Commission issued a plain English guide “Disclosures 101 for Social Media Influencers” (the “2019 Guide”). The 2019 Guide is a clear and unambiguous warning to social media influencers that they,...more
The International Chamber of Commerce (the “ICC”) has issued INCOTERMS® 2020 (short for International Commercial Terms) to be effective January 1, 2020. INCOTERMS 2020 provides an updated template and standardized set of...more