In the last few weeks, the Financial Crimes Enforcement Network (FinCEN) has circulated several instructions focusing on money services businesses operating in the southwest United States, answering the current Administration’s call for increased security measures in that area.
On March 11, FinCEN issued a Geographic Targeting Order (GTO) adding more requirements to certain money services…
The guidance U.S. companies have been waiting for after years of ups and downs is finally here. In line with our last update, on March 21, 2025, FinCEN issued an interim final rule exempting U.S. companies and persons from the requirement to report, modify, or correct beneficial ownership information under the Corporate Transparency Act…
After the Financial Crimes Enforcement Network (FinCEN) stated that it would hold off on taking enforcement actions against Reporting Companies for failure to comply with the March 21, 2025, deadline under the Corporate Transparency Act (CTA), the U.S. Department of the Treasury announced its own intention to limit CTA enforcement to foreign companies.…
The Financial Crimes Enforcement Network (FinCEN) published new guidance on Feb. 27, 2025, putting its plan to begin enforcing the Corporate Transparency Act (CTA) on hold. After the Feb. 17 order by the U.S. District Court for the Eastern District of Texas in Smith v. United States Department of Treasury made the CTA once again…
In our last update, we reported that despite the Supreme Court staying the nationwide injunction against FinCEN’s enforcement of the CTA in one Texas case, a nationwide stay of the Reporting Rule granted by a federal judge in the Eastern District in Smith v. United States Department of Treasury (6:24-cv-00336) remained in effect. …
Since the President signed the February 10, 2025 Executive Order (Order) pausing enforcement of the Foreign Corrupt Practices Act (FCPA) (Client Alert: President Trump issues Executive Order “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security”), companies with cross-border business operations have likely faced questions from both internal and…
Last night, in a move with wide-ranging implications for American companies doing business abroad, President Trump issued an executive order (Order) temporarily halting enforcement of the Foreign Corrupt Practices Act (FCPA). The Order directs Attorney General (AG) Pam Bondi to review guidelines and policies governing FCPA investigations and enforcement actions in the next 180 days,…
This past Thursday, New York Attorney General Letitia James issued a warning to businesses against price gouging for eggs and poultry. The current bird flu outbreak began in March 2024 but has become a topic of increasing concern for consumers and businesses in the new year after more than 13 million hens—necessary to the success…
On February 1, 2025, the Trump Administration imposed long-expected tariffs on imports from Canada, Mexico, and China through the issuance of three executive orders (“EOs”). While some recent reporting suggested that implementation of these tariffs may be delayed to March 1, 2025, the White House confirmed on January 31, 2025 that these tariffs…
As he enters his second week in office, President Donald Trump is forecasting a desire to implement a muscular trade policy leaning heavily on the imposition of tariffs—potentially on a global basis—as a means of extracting favorable trade deals and other economic and political concessions from trading partners across the globe. As of this writing,…
