On March 21, 2025, the Financial Crimes Enforcement Network of the U.S. Treasury Department (“FinCEN”) narrowed the scope of the beneficial ownership information (“BOI”) filing requirement under the Corporate Transparency Act...more
FinCEN announced that by March 21, 2025, it plans to issue an interim final rule that will extend the current beneficial ownership information (BOI) reporting deadlines under the Corporate Transparency Act. Until the new rule...more
The Corporate Transparency Act (CTA) is back in effect − at least for now − and companies covered by the CTA are once again required to file beneficial ownership information (BOI) reports with FinCEN. On February 17, 2025, in...more
On January 23, 2025, the U.S. Supreme Court vacated one nationwide stay (Texas Top Cop Shop, Inc. v. McHenry – formerly, Texas Top Cop Shop v. Garland) which blocked the U.S. government from enforcing the Corporate...more
The Department of Justice has finalized prohibitions and restrictions on cross-border transfers of certain data to China and other “Countries of Concern” (as defined below). It seeks to address what is, in the U.S....more
1/21/2025
/ Artificial Intelligence ,
China ,
Cuba ,
Data Privacy ,
Data Security ,
Department of Justice (DOJ) ,
International Data Transfers ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
National Security ,
Personal Data ,
Russia
The Department of Justice (DOJ) has proposed a significant restriction on cross-border transfers of sensitive personal data to designated “countries of concern.” The goal is to address national security risks posed by...more
12/13/2024
/ Biometric Information ,
CFIUS ,
Cybersecurity Information Sharing Act (CISA) ,
Data Protection ,
Department of Justice (DOJ) ,
International Data Transfers ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Personal Data ,
Popular ,
Proposed Rules
A federal judge has blocked the U.S. government from enforcing the Corporate Transparency Act (CTA) and its implementing regulations nationwide. As a result, companies affected by the CTA do not have to report information...more
Financial institutions face significant new compliance obligations under export control guidance issued by the Commerce Department’s Bureau of Industry and Security (BIS) last month. ...more
The deadline is quickly approaching for companies created or registered to do business in the United States before 2024 to report beneficial ownership information as required by the Corporate Transparency Act (CTA). The CTA...more
On September 6, 2024, the Bureau of Industry and Security (BIS) of the U.S. Commerce Department issued an interim final rule expanding export controls on certain emerging technologies: Quantum Computing: Quantum computers,...more
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a rule to counter money laundering and the financing of terrorism that would add significant compliance requirements for financial...more
The United States has substantially expanded economic sanctions and export controls targeting Russia and Belarus, imposing new restrictions that could have a major impact on companies with business activities in or relating...more
The 21st Century Peace Through Strength Act became law recently as part of H.R. 815, which also provided aid to Ukraine, Israel and Taiwan. The law contains important sanctions measures that: Extend the statute of...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced two enforcement actions this year. Both reference the Financial Crimes Enforcement Network's (FinCEN) whistleblower program,...more
In a display of the United States' jurisdictional reach, the Justice Department has indicted KuCoin, a prominent global cryptocurrency exchange, along with founders Chun Gan and Ke Tang, for Bank Secrecy Act (BSA) and...more
President Biden issued an executive order on December 22, 2023 targeting evasion of U.S. sanctions on Russia. Executive Order 14,114: Authorizes sanctions on foreign financial institutions (“FFIs”) determined to have...more
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has issued a final rule (the Access Rule) regarding access to and use of beneficial ownership information (BOI) maintained by FinCEN....more
On June 1, the Supreme Court ruled that entities that submit false claims to the government can be liable if they subjectively believed the claims were false at the time of submission. ...more