On May 12, 2025, the US Department of Justice’s (DOJ) Criminal Division issued a memorandum titled Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime (the Memo) to all Criminal Division personnel. The...more
5/19/2025
/ Corporate Crimes ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
New Guidance ,
Self-Reporting ,
Trump Administration ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
The final judicial barrier to the Financial Crimes Enforcement Network’s enforcement of the Corporate Transparency Act’s beneficial ownership information (BOI) reporting requirements has been lifted.
The Corporate...more
On December 26, 2024, the US Court of Appeals for the Fifth Circuit changed course, effectively reinstating the preliminary injunction enjoining enforcement of the Corporate Transparency Act (CTA)....more
12/31/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reinstatement ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays ,
Time Extensions ,
Vacated
On December 3, 2024, the US District Court in the Eastern District of Texas (the Texas Federal Court) granted a nationwide preliminary injunction in favor of certain small businesses, ruling (1) the Corporate Transparency Act...more
12/17/2024
/ Beneficial Owner ,
Business Ownership ,
Corporate Transparency Act ,
Disclosure Requirements ,
FinCEN ,
Injunctions ,
Popular ,
Preliminary Injunctions ,
Reporting Requirements ,
Small Business ,
Suspended Judgment ,
Unconstitutional Condition
The booklet summarises key financial crime related legal and regulatory changes expected over the next 18 months to 2 years, as well as providing electronic links to key resources.
Key developments:
- US Supreme Court...more
10/3/2024
/ Chevron Deference ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
FBAR ,
Financial Crimes ,
IRS ,
Legislative Agendas ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Agenda ,
Regulatory Reform ,
SCOTUS ,
Whistleblower Protection Policies
The Department of Justice has announced yet another pilot program, adding to their “mix of carrots and sticks” designed “to promote responsible corporate citizenship.” The new whistleblower pilot program, which is still under...more
3/25/2024
/ Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Extortion ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On March 1, 2024, the United States District Court for the Northern District of Alabama found that the Corporate Transparency Act (CTA) is unconstitutional because it exceeds Congress’ legislative power. The 53-page opinion...more
“Call us before we call you.” With this message, on January 10, 2024, the Southern District of New York announced the SDNY Whistleblower Pilot Program (Pilot Program), which seeks to encourage individual participants in...more
1/25/2024
/ Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Non-Prosecution Agreements ,
Pilot Programs ,
Voluntary Disclosure ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
Plaintiffs have filed two putative class action complaints in 2023, alleging violations of New York City’s relatively new biometric information privacy law, signaling a new potential avenue for class action plaintiffs’ lawyer...more
For several years, companies that collect, use, and store the biometric information of Illinois residents have lived in fear of violating the Biometric Information Privacy Act (BIPA), due to a tidal wave of class action...more
3/9/2023
/ Attorney's Fees ,
Biometric Information ,
Biometric Information Privacy Act ,
Cause of Action Accrual ,
Class Action ,
Data Collection ,
Data Privacy ,
Fingerprints ,
IL Supreme Court ,
Jury Verdicts ,
Privacy Laws ,
Statute of Limitations ,
Statutory Violations
On February 22, 2023, the US Department of Justice issued a nationwide policy for all US Attorney’s Offices (USAOs) outlining the circumstances in which a company may receive credit for voluntary self-disclosure (VSD)....more
The US Drug Enforcement Agency (DEA) recently stated that delta-8 THC acetate ester (delta-8 THCO) and delta-9 acetate ester (delta-9 THCO) are not hemp, but Schedule I controlled substances under the Controlled Substances...more
The FDA’s recent decision not to regulate CBD like a food or dietary supplement leaves a multi-billion-dollar industry in a lurch. What’s next, and what should companies do now?...more
Certain companies will soon have to give the Financial Crimes Enforcement Network (FinCEN) a look behind the corporate veil. In December 2021, FinCEN issued a Notice of Proposed Rulemaking (NPRM) seeking comment on one...more
Citibank’s balance sheet is likely breathing a sigh of relief. A Second Circuit panel held that the bank may finally recoup nearly $500 million in funds that it inadvertently wired to lenders almost two years ago. US...more
As any fan of Sherlock Holmes can attest, identifying a person through their unique biological characteristics, such as fingerprints, is nothing new. Harnessing the power of cutting-edge technology and Artificial Intelligence...more
Supreme Court leaves TCPA intact; strikes down exception for government debt collection -
The Telephone Consumer Protection Act (TCPA) remains in place, but the exception permitting robocalls for government debt...more
3/26/2021
/ ATDS ,
Auto-Dialed Calls ,
Barr v American Association of Political Consultants Inc ,
Caller ID Services ,
Constitutional Challenges ,
FCC ,
First Amendment ,
Free Speech ,
Prior Express Consent ,
Regulatory Requirements ,
Robocalling ,
SCOTUS ,
Spoofing ,
TCPA
In a major development for companies that collect, use, and store biometric data, the US Federal Trade Commission (FTC) reached a proposed settlement of a complaint against a company that allegedly deceived consumers about...more
1/20/2021
/ Biometric Information ,
California Consumer Privacy Act (CCPA) ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Corporate Counsel ,
Data Collection ,
Data Privacy ,
Enforcement Actions ,
Facial Recognition Technology ,
Federal Trade Commission (FTC) ,
FTC Act ,
General Data Protection Regulation (GDPR) ,
Misrepresentation ,
Photographs
Speaking at the July 29 meeting of the ABA Section on Taxation, Practice and Procedure, Internal Revenue Service (IRS) officials and Chief Counsel shared a look behind the scenes of recent IRS implementation and enforcement...more