The Corporate Transparency Act (CTA) has been in effect since Jan. 1, 2024, requiring non-exempt U.S. entities and non-exempt foreign entities that are registered to do business in the United
Continue Reading CTA Countdown: Upcoming FinCEN Filing Deadlines
On July 30, 2024, the SEC announced it had reached a settlement agreement with Western, a dually registered investment adviser and broker-dealer providing investment advice and brokerage services to retail
Continue Reading Reg BI Enforcement Intensifies: SEC Fines Western International Securities for Violating Care and Compliance Obligations
On June 17, 2024, the FTC filed a federal court complaint against Adobe and two of its executives. The complaint alleges that Adobe deceived consumers by failing to adequately disclose
Continue Reading FTC Targets Adobe for Hidden Fees and Deceptive Subscription Practices
On June 5, 2024, the U.S. Court of Appeals for the Fifth Circuit unanimously vacated a rule the Securities and Exchange Commission (SEC) enacted in August 2023 that was intended to protect investors who invest in certain private funds and prevent fraud by the investment advisers to Private Funds.
Continue Reading U.S. Appeals Court Vacates SEC Private Fund Adviser Rule
On March 1, 2024, Judge Liles C. Burke of the U.S. District Court for the Northern District of Alabama found the Corporate Transparency Act (CTA or Act) unconstitutional on the
Continue Reading District Court Declares Corporate Transparency Act Unconstitutional
The Securities and Exchange Commission (SEC)’s Spring 2023 Unified Agenda of Regulatory and Deregulatory Actions (the Agenda) forecast a busy fall for the regulator, with many of the 55 final
Continue Reading Assessment of the SEC’s Progress on Its 2023 Rulemaking Agenda
On April 18, 2023, Department of Commerce Assistant Secretary for Export Enforcement Matthew Axelrod issued a memorandum (Memorandum) that, while primarily focused on enforcement of export control restrictions, offered some
Continue Reading Expansive New Bank Secrecy Act, Sanctions Whistleblower Program: Department of Commerce Insights
On Sept. 21, 2020, the Office of the Comptroller of the Currency (the OCC) issued guidance pertaining to whether national banks could hold stablecoin reserves. That same day, the Securities
Continue Reading The OCC and SEC’s FinHub Issue Guidance on Fiat-Backed Stablecoin Reserves
The U.K.’s Criminal Finances Act 2017 provides law enforcement with new powers to obtain orders to freeze bank accounts and apply for forfeiture orders, permanently depriving the account holder of
Continue Reading Prove It or Lose It! Part III: A Step Too Far? Account Freezing Orders & Account Forfeiture Orders in the UK