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FinCEN and the U.S. Treasury Department Suspend CTA Enforcement – Forthcoming Rule to Narrow CTA Compliance to Foreign Reporting...

On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced a suspension of enforcement actions related to the Corporate Transparency Act (“CTA”). This announcement means that reporting companies are...more

Corporate Transparency Act: Once Again Enforceable – New Compliance Dates Apply

As we previously discussed, on January 7, 2025, the U.S. District Court for the Eastern District of Texas issued a nationwide injunction delaying the implementation of the Corporate Transparency Act’s (“CTA”) reporting...more

Future of FCPA Enforcement Uncertain (For Now) as New Administration Revamps the Law Enforcement Toolkit

Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt...more

World Bank Group’s Watchful Eye: A Reminder of How Minor Ethical Breaches Can Result in Major Problems

While much attention is given to compliance with applicable laws, such as the U.S. Foreign Corrupt Practices Act of 1977, many companies working on projects sponsored by Multi-Lateral Development Banks (“MDBs” or “MDB”)...more

DOJ Warns Against Unintelligent Use of Artificial Intelligence

The Department of Justice is stepping up its focus on artificial intelligence (“AI”), with officials warning that harsher penalties could be in store for those who deliberately misuse the technology to commit white collar...more

New CFTC Enforcement Policy Increases Penalties to Deter Recidivists

The U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) — the federal agency tasked with regulating the U.S. derivatives markets, which includes futures, swaps and certain kinds of options — has recently taken...more

Holiday Jeers: How The Grinch at DOJ May Make It Harder for Companies to Stay on the Nice List This Christmas

With the holiday season upon us, companies waiting for a nice surprise this Christmas are more likely to find a lump of coal in their stocking. In a series of recent announcements, Department of Justice (“DOJ”) officials have...more

World Bank’s “Major Initiative” Should Enhance Evaluations Of Corporate Compliance Programs

During a roundtable at the Fifth International Debarment Colloquium last month, Joseph Mauro, a spokesperson for the Compliance Unit of the World Bank Group’s (“World Bank”) Integrity Vice Presidency (“INT”), announced recent...more

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