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Treasury Department Halts Enforcement of CTA Reporting Obligations

On March 2, 2025, the U.S. Treasury Department announced that it would not enforce penalties or fines associated with beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA)...more

FinCEN Reinstates CTA Reporting Obligations

On February 18, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced that beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are...more

Increased Immigration Enforcement: Beware and Prepare for I-9 Audits

On January 20, 2025, on his first day in office, President Trump issued several sweeping executive orders intended to advance his immigration agenda. These measures will undoubtedly lead to an increase in immigration...more

What to Do If ICE Comes to Your Workplace?

With the return of more aggressive immigration policies under the administration of President Trump, now is a critical time for employers to ensure they are in compliance with immigration laws and have taken steps to protect...more

CTA Compliance Restored

On December 23, 2024, the United States Court of Appeals for the Fifth Circuit reinstated the immediate enforceability of the Corporate Transparency Act (CTA). In the case Texas Top Cop Shop, Inc. v. Garland, a three-judge...more

CTA Alert: Texas Court Puts the Brakes on the Nationwide Enforcement of the Corporate Transparency Act

On December 3, 2024, in Texas Top Cop Shop, Inc., et al. v. Garland, et al. (Case No. 4:24-cv-478-ALM), the U.S. District Court for the Eastern District of Texas issued a preliminary nationwide injunction against the...more

CFPB Pushes Move to an Open Banking System with the Personal Financial Data Rights Rule and Sparks Immediate Court Challenges from...

On Tuesday, the Consumer Financial Protection Bureau (CFPB) released the final version of the Personal Financial Data Rights Rule that requires many financial institutions, credit card issuers, and other financial service...more

It’s a Win-Win for California Employers

This spring, California employers received two rare and substantial victories, alleviating some of the burden caused by frequent and costly wage and hour claims that plague California businesses. In 2023 alone, California’s...more

California’s Sweeping Workplace Violence Prevention Law

The leading cause of worker fatalities after transportation incidents and falls, is workplace violence. A law affecting all but a few California employers comes into force on July 1, 2024 to address this issue. Existing...more

Waters No Less Rocky After Landmark BIPA Settlement

Waters No Less Rocky After Landmark BIPA Settlement - A year and a half has passed since one of the most remarkable jury verdicts in Illinois history. The Rogers v. BNSF case was the first Illinois Biometric Information...more

Justice Department Files Appeal in CTA Enforceability Case

As discussed in our previous client advisory, earlier this month, the U.S. District Court for the Northern District of Alabama entered a final declaratory judgment concluding that the Corporate Transparency Act (“CTA” or the...more

Instructions for Filing Beneficial Ownership Information Reports under the Corporate Transparency Act

On January 1, 2024, the new beneficial ownership information reporting requirements (BOIR) went into effect under the Corporate Transparency Act (CTA). Among other things, beneficial ownership reporting is intended to make it...more

Fifth Circuit Upholds Nasdaq Board Diversity Rule in Alliance for Fair Board Recruitment, National Center for Public Policy...

On October 18, 2023, the United States Court of Appeals for the Fifth Circuit in Alliance for Fair Board Recruitment v. SEC, 5th Cir., No. 21-60626 upheld Nasdaq’s board diversity rule, which encourages greater board...more

FinCEN Extends Beneficial Reporting Deadline for Companies Created or First Registered in 2024

The Corporate Transparency Act (CTA), which becomes effective on January 1, 2024, creates novel obligations for millions of entities to report beneficial ownership information (BOI) and certain other information to the U.S....more

FinCEN Identifier: The Final Rule Details What You Need to Know

Under the Corporate Transparency Act (CTA), which we have previously written about, reporting companies are required to report to the Financial Crimes Enforcement Network (FinCEN) certain identifying information about...more

CFPB Issues Proposed Rule to Expand Supervisory Authority, Conduct Examinations of Digital Wallets and Mobile Payment Apps

Yesterday, the Consumer Financial Protection Bureau (CFPB) released a notice of proposed rulemaking that would allow the agency to supervise and conduct examinations of certain non-bank providers of digital wallets and...more

FinCen Issues Small Entity Compliance Guidance: An Approach to BOI Reporting Obligations

The US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published its Small Entity Compliance Guide (the ​“Guide”) for the Corporate Transparency Act (the ​“CTA”) on September 18, 2023. The Guide...more

The Corporate Transparency Act: New Compliance & Reporting Obligations

On January 1, 2024, the Corporate Transparency Act (the “CTA”) comes into effect for reporting companies formed after that date, with reporting for existing companies taking effect a year later. With approximately six months...more

BIPA Becomes the Monster Employers Feared

Two momentous decisions regarding the Illinois Biometric Information Privacy Act (BIPA) recently came down from the Illinois Supreme Court. First, the Court recently ruled in Cothron v. White Castle System Inc. that a BIPA...more

BIPA Goes on Trial

The Illinois Biometric Information Privacy Act (BIPA) has been on the books as one of the nation’s most protective biometric privacy statutes since 2008. It was also one of the first to give individuals a cause of action for...more

With Regulation in Flux, the SEC Disapproves Proposed Grayscale Investments’ Spot Bitcoin ETF

On June 29, 2022, the Securities and Exchange Commission (SEC) rejected Grayscale Investments’ proposal to convert Grayscale® Bitcoin Trust (OTCQX: GBTC) to a spot Bitcoin ETF. See SEC Order Disapproving a Proposed Rule...more

FinCEN Warns Of Russia Sanctions Evasion; Focus on Crypto

On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) issued an alert advising financial institutions to be vigilant against attempts to evade recent U.S. sanctions imposed on Russia’s following that country’s...more

Unauthorized Blockchain Domain Names: What's a Brand to Do?

Just when you thought you had a handle on domain name enforcement, blockchain technology has given rise to blockchain domain names, which bring novel and complex challenges. There are currently millions of blockchain domain...more

Privilege and the Tripartite Insurer-Insured-Counsel Relationship

The tripartite insurer-insured-counsel relationship requires the insurer, its insured and the insured’s counsel to communicate with each other in the defense of a claim. In general, all parties work together to come to a...more

Explaining Cryptocurrency’s Ransomware Problem

The recent ransomware attacks on Colonial Pipeline and JBS led to a flurry of calls to ban Bitcoin (and cryptocurrency generally) as enabling and incentivizing these attacks. Given the difficulty of tracking the...more

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