In a striking decision on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction in favor of the plaintiffs in Texas Top Cop Shop, Inc. et al. v. Garland. The...more
12/5/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays
The Department of the Treasury's Office of Foreign Assets Control (“OFAC”) was active in October and November 2024. After issuing an Updated Price Cap Coalition Advisory for the Maritime Oil Industry and Related Sectors on...more
As the incoming Trump administration prepares to take office, businesses and investors can expect significant shifts in the enforcement priorities of the Securities and Exchange Commission (SEC) and the Commodity Futures...more
11/12/2024
/ Anti-Money Laundering ,
CFIUS ,
CFTC ,
Corporate Transparency Act ,
Cryptoassets ,
Cryptocurrency ,
Disclosure Requirements ,
Diversity and Inclusion Standards (D&I) ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
FinCEN ,
Foreign Investment ,
Insider Trading ,
Investors ,
National Security ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Trade Relations ,
Trump Administration
On October 21, 2024, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) issued an Updated Price Cap Coalition Advisory for the Maritime Oil Industry and Related Sectors (“Updated Advisory”). OFAC...more
10/30/2024
/ Best Practices ,
Capital Markets ,
Environmental Policies ,
Fixed Price ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Regulatory Requirements ,
Sanctions ,
Stakeholder Engagement ,
Transparency ,
Vessels
On July 23, 2024, the Committee on Foreign Investment in the United States (CFIUS) published its Annual Report to Congress for the Calendar Year 2023. The report provides key statistics on the CFIUS process and the...more
On April 24, 2024, President Biden signed into law the 21st Century Peace through Strength Act, Pub. L. No. 118-50 (the “Act”). By doing so, the statute of limitations (“SoL”) for violations, both criminal and civil, of IEEPA...more
The government had another busy year in 2023, investigating and prosecuting healthcare fraud cases on multiple fronts. Contending with the enormous healthcare crises of the now-concluded COVID-19 pandemic and the ongoing...more
7/3/2024
/ Anti-Corruption ,
BlackRock ,
Congressional Investigations & Hearings ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Educational Institutions ,
Enforcement ,
Enforcement Actions ,
Export Controls ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Healthcare Fraud ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Tennessee
On April 23, 2024, the European Parliament adopted, by an overwhelming 555-6 majority, a landmark law that will establish a sweeping and forceful regulatory regime to prohibit any products made using forced labor from being...more
As reported in our previous client alert, on May 14, 2024, President Biden announced that he directed his Trade Representative to increase tariffs under Section 301 of the Trade Act of 1974 (Section 301) on a wide range of...more
6/5/2024
/ China ,
Comment Period ,
Electric Vehicles ,
Exclusions ,
Imports ,
Lithium Batteries ,
Medical Supplies ,
Minerals ,
Public Comment ,
Section 301 ,
Semiconductors ,
Tariffs ,
Technology ,
USTR
On May 14, 2024, President Biden announced that he is directing his Trade Representative to increase tariffs under Section 301 of the Trade Act of 1974 on a wide range of Chinese goods, which will significantly impact U.S....more
5/22/2024
/ Anti-Dumping Duty ,
Biden Administration ,
China ,
Countervailing Duties ,
Duty Free ,
Electric Vehicles ,
Imports ,
Manufacturers ,
Section 201 ,
Semiconductors ,
Solar Panels ,
Tariffs ,
Trade Act of 1974 ,
US Trade Policies ,
USTR
Throughout 2023 and early 2024, we continue to witness deepening geopolitical and economic divides globally. The U.S. and its allies (most significantly the EU and the G7), spurred on by Russia’s war in Ukraine, continue to...more
5/8/2024
/ China ,
Department of Justice (DOJ) ,
EU ,
G7 ,
Geopolitical Risks ,
International Trade ,
Iran ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
Trade Relations ,
Ukraine
License Exception MED -
On April 25, 2024, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced a final rule for a new license exception for “medical devices” under § 740.23 of the EAR (“License...more
5/3/2024
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exporters ,
Exports ,
General Licenses ,
Licensing Rules ,
Medical Devices ,
Russia ,
Ukraine
On April 12, 2024, in coordination with the United Kingdom, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two new Determinations (collectively, the “Determinations”) that together prohibit...more
On April 10, 2024, U.S. Customs and Border Protection (“CBP”) issued a Withhold Release Order (“WRO”) on a Chinese company, Shanghai Select Safety Products Co., Ltd. (“Shanghai Select”) and its two subsidiaries, Select...more
4/22/2024
/ China ,
Customs and Border Protection ,
Goods or Services ,
Human Rights ,
Importers ,
Imports ,
Manufacturers ,
Supply Chain ,
US Trade Policies ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Withhold Release Orders (WROs)
This is the tenth in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. Our previous post, "Health Care Fraud Enforcement in 2024," can be found here....more
4/18/2024
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
US Trade Policies ,
White Collar Crimes
On January 29, 2024, BIS proposed a rule that would impose new requirements for U.S. providers of Infrastructure as a Service (“IaaS”) products and their foreign resellers. The proposed rule would require U.S. IaaS providers...more
The U.S. Federal District Court for the District of Alabama (the “District Court”) ruled on March 1, 2024, that the Corporate Transparency Act (“CTA”) was unconstitutional. Presiding over the case was Judge Liles Burke, who...more
On February 23, 2024, the Biden administration announced more than 500 sanctions on individuals and entities inside the Russian Federation and entities outside of Russia determined to be supporting Russia’s war effort....more
Customs and Border Protection Impounds Thousands of Volkswagen Vehicles -
On February 14, 2024, it was reported that U.S. Customs and Border Protection (“CBP”) had impounded thousands of Volkswagen Group’s (“Volkswagen”)...more
What is the purpose of the Corporate Transparency Act (“CTA”)?
Effective as of January 1, 2024, the Corporate Transparency Act (“CTA”) imposed new federal reporting obligations on certain companies, including potentially...more
The Corporate Transparency Act (“CTA”) imposes on many companies (both domestic and foreign entities registered to do business in the U.S.) new federal reporting obligations including providing information on the beneficial...more
On December 22, 2023, President Biden issued a new Executive Order affecting foreign financial institutions and those importing certain goods into the U.S.
In addition, OFAC provided related new and revised FAQs, as well...more
The U.S. Congress has passed the Foreign Extortion Prevention Act (“FEPA”), as part of the National Defense Authorization Act for Fiscal Year 2024 (“NDAA”). On December 14, 2023, the measure was sent to President Biden, who...more
On November 29, 2023, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced that it was amending the beneficial ownership information (“BOI”) reporting rule (the “BOI Reporting Rule”) to...more
U.S. authorities have been active in November 2023, reinforcing and expanding sanctions targeting Russia's war effort in Ukraine. Multiple agencies added sanctions targeting entities involved in Russia's military supply...more