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No Hearing? No Money: Second Circuit Holds the Government May Not Keep Illegally Seized Rent

The Second Circuit has recently held that the Government must account for rental income it denied a property owner during a period of illegal seizure even though the Government was able to establish probable cause at a...more

[Ongoing Program] Private Credit Summit 2021 - March 16th, 9:30 am ET

From February 23 – March 18th Proskauer will host its second annual Private Credit Summit. This interactive virtual event will bring together leaders in the Private Credit industry, including lenders, private equity firms,...more

The Corporate Transparency Act – Government KYC

Summary of the Corporate Transparency Act under the National Defense Authorization Act for Fiscal Year 2021 - On January 1, 2021, the Corporate Transparency Act (the “CTA”), which is part of the National Defense...more

Chinese Military Companies Trading Ban: Overview of OFAC’s Ongoing Guidance

On November 12, 2020, the Trump Administration issued an Executive Order prohibiting U.S. persons from trading securities and related derivatives in “Communist Chinese Military Companies” (CCMCs), effective 60 days later on...more

Regulatory Crackdown on Ransomware

Ransomware is a Serious and Growing Problem - In recent years, Ransomware has evolved from merely encrypting files/disabling networks in solicitation of ransom, to sophisticated attacks that often involve actual data...more

FinCEN Explains What Guides Its Enforcement Decisions

On August 18, 2020, the Financial Crimes Enforcement Network (FinCEN), which is the primary regulator and administrator of the Bank Secrecy Act (BSA), issued a statement on enforcement of the BSA. The requirements of the BSA...more

Rear View Mirror: Criminal Exposure for Companies that Received PPP Loans Under the CARES Act

On April 28, 2020, Treasury Secretary Mnuchin announced that companies that received loans of more than $2 million through the Paycheck Protection Program (“PPP”) of the CARES Act will be closely scrutinized. Mr. Mnuchin’s...more

Cybersecurity and Fraud Risks for Fund Managers in the Wake of Coronavirus

COVID-19 has created many new concerns for private fund managers; however, managers should be particularly mindful of heightened cybersecurity and fraud risks. With increased numbers of employees teleworking, there are...more

Top Ten Regulatory and Litigation Risks for Private Funds in 2020

The private fund industry is more in the public eye than ever before. Private capital and private markets have experienced massive growth over the last two decades, substantially outpacing the growth of public equity. We have...more

New York Establishes Six-Year Statute of Limitation for Prosecution of Claims under the Martin Act

On August 25, 2019, New York Governor Andrew Cuomo signed New York State Senate Bill S6536 which established a six-year statute of limitations for the prosecution of certain crimes related to fraudulent practices in respect...more

D.C. Circuit Expands U.S. Prosecutors' Reach Over Foreign Bank Documents

In a recent decision, the U.S. Court of Appeals for the D.C. Circuit unanimously affirmed a district court order compelling three Chinese banks (not currently identified) to produce financial records in response to subpoenas...more

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