Subject to Inquiry

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In recent years, the Biden Administration has been vocal that combatting foreign public corruption is a key pillar of its national security efforts.[1]  Consistent with those policy goals, on December 22, 2023, Congress passed the Foreign Extortion Prevention Act (FEPA), a long-awaited complement to the Foreign Corrupt Practices Act (FCPA).  Where the FCPA

On December 23, 2023, New York Governor Kathy Hochul signed the New York LLC Transparency Act (“NYLTA”), which requires LLCs to disclose beneficial ownership information (“BOI”) to the New York Department of State.  Effective December 21, 2024, the NYLTA will impose separate BOI reporting requirements on New York LLCs, which are also subject to the

For U.S. businesses, sanctions compliance has never been more challenging or more important.  The U.S. has responded to Russia’s invasion of Ukraine with a broad range of sanctions targeting the Russian government, its officials, oligarchs and Russia’s financial and energy industries, among others.  Indeed, since the invasion of Ukraine, the agency that administers sanctions, the

On January 16, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance to incentivize voluntary self-disclosure (“VSD”) of possible violations of the Export Administration Regulations (“EAR”). This new guidance—which was announced in conjunction with a speech by BIS’s top enforcement official indicating the EAR enforcement is an increasingly important priority

During a summit celebrating its one-year anniversary, the Disruptive Technology Strike Force provided updates on its efforts to prevent authoritarian regimes and hostile nation-states from acquiring critical technologies.

Read on for details about a new expansion of the effort, recent prosecutions and the group’s continued focus on cases involving theft of trade secrets and export

The Bank Secrecy Act (“BSA”) establishes program, recordkeeping, and reporting requirements for certain financial institutions to combat and detect money laundering, terrorist financing, and other illicit activities.  On February 13, 2024, FinCEN proposed new rules which expand the scope of the BSA to include certain investment advisers, which currently are not subject to any federal

Rule Regarding Access to Beneficial Ownership Information Takes Effect

On February 21, 2024, FinCEN published a Small Entity Compliance Guide to aid in compliance with the Corporate Transparency Act’s (“CTA”) Beneficial Ownership Information (“BOI”) Access and Safeguards Rule (“Access Rule”).  The Compliance Guide is called the Small Entity Compliance Guide only because federal law requires

On February 1, 2024, the G7+ Coalition (consisting of the G7, the European Union, and Australia) published an Oil Price Cap (OPC) Compliance and Enforcement Alert (the “Alert”), identifying notable OPC evasion methods and recommending various methods to reduce the risk of evasion and its negative impacts.  The OPC was enacted in December 2022 in

RELATED UPDATE: Deputy Attorney General Monaco Announces New DOJ Whistleblower Program (March 8, 2024)

As of January 1, 2024, the Corporate Transparency Act (“CTA”) has gone into effect. Companies that may be Reporting Companies of Beneficial Ownership Information (“BOI”) should be aware of three key aspects of the CTA.

  • One, entities formed on or after

Corporate Transparency Act Beneficial Ownership Reporting Requirements to Take Effect

In 2021, the Corporate Transparency Act (“CTA”) was enacted as part of the Anti-Money Laundering Act of 2020, requiring certain business entities (“Reporting Companies”) to report beneficial ownership information (“BOI”) to the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”).  FinCEN issued the final