News & Analysis as of

Compliance Department of Justice (DOJ) Appeals

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Paul Hastings LLP

Fourth Circuit Court of Appeals Stays Preliminary Injunction of Anti-DEI Executive Order

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On March 14, 2025, the Fourth Circuit Court of Appeals stayed the nationwide preliminary injunction previously issued by the District of Maryland, which had enjoined certain aspects of Executive Order No. 14173, President...more

Hinckley Allen

What to Know: Injunction of Certain Trump DEI Executive Order Provisions Lifted

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On March 14, 2025, the U.S. Court of Appeals for the Fourth Circuit granted the government’s request to stay a Maryland federal judge’s nationwide preliminary injunction that temporarily stopped three key provisions of...more

White & Case LLP

US Supreme Court Rejects Application of Commingling Theory in Holocaust Expropriation Case

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On February 21, 2025, the US Supreme Court issued a unanimous decision in Republic of Hungary v. Simon, further narrowing the scope of the Foreign Sovereign Immunities Act's exception to sovereign immunity for expropriation...more

Skadden, Arps, Slate, Meagher & Flom LLP

First Circuit Demands ‘But For’ Causation Between Alleged Kickback and Claim Submission

On February 18, 2025, a panel of the U.S. Court of Appeals for the First Circuit unanimously decided that in order to transform an Anti-Kickback Statute (AKS) violation into a false or fraudulent claim for purposes of False...more

Morrison & Foerster LLP

What Now? President Trump's DEI Executive Orders Temporarily Paused

On February 21, 2025, a federal district court in Maryland issued a nationwide injunction, temporarily preventing enforcement of three key provisions of President Trump’s executive orders targeting DEI programs. Specifically,...more

McCarter & English, LLP

The Evolution of the CTA: Beneficial Ownership Information Reports Are Due by March 21, 2025

As of February 18, 2025, the US Department of the Treasury Financial Crimes Enforcement Network’s (FinCEN) Corporate Transparency Act (CTA) reporting requirements have been restored—at least temporarily. The new filing...more

Vinson & Elkins LLP

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

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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

Proskauer Rose LLP

Ping Pong Rules: Corporate Transparency Act Back in Effect (Again)

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On February 18, 2025, U.S. District Judge Jeremy Kernodle of the Eastern District of Texas stayed his prior injunction against enforcement of the Corporate Transparency Act (the “CTA”) pending appeal by the U.S. Department of...more

Wiley Rein LLP

Corporate Transparency Act Reinstated; New March Deadline for BOI Reports

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As discussed last month, in early January, the U.S. District Court for the Eastern District of Texas issued a nationwide injunction temporarily blocking enforcement of the Corporate Transparency Act (CTA) (see Smith et al....more

Kerr Russell

Corporate Transparency Act Enforcement Expected to Resume Following Legal Developments

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While the United States Supreme Court recently lifted one nationwide injunction against enforcement of the Corporate Transparency Act (CTA) in the case of Texas Top Cop Shop, Incorporated et al. v. McHenry (formerly Garland),...more

Holtzman Vogel Baran Torchinsky & Josefiak

In-Compliance: Holtzman Vogel's January 2025 Round-Up

Supreme Court Lifts Fifth Circuit’s Corporate Transparency Act Injunction; Second District Court Enjoins Beneficial Ownership Reporting Rule and Requirements Remain Fluid - On January 23, 2025, the U.S. Supreme Court...more

Foley Hoag LLP

Corporate Transparency Act Remains Subject to Nationwide Preliminary Injunction Despite Supreme Court Ruling

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On January 23, 2025, the U.S. Supreme Court stayed a nationwide preliminary injunction of the Corporate Transparency Act (“CTA”) previously issued by the U.S. Federal District Court for the Eastern District of Texas (Texas...more

Husch Blackwell LLP

Nationwide Injunction Halts Enforcement of the Corporate Transparency Act -

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As of the posting of this article, reporting companies nationwide do not need to comply with the Corporate Transparency Act’s (CTA) revised beneficial owner information (BOI) reporting deadlines, though the situation may...more

Wiley Rein LLP

CTA Update: Supreme Court Temporarily Lifts Injunction, but Requirements Remain Blocked

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On January 23, 2025, the U.S. Supreme Court issued a ruling that appears to settle – for now – a nearly two-month-long legal battle over the Corporate Transparency Act (CTA), which began with a nationwide preliminary...more

Amundsen Davis LLC

U.S. Supreme Court Provisionally Reinstates the Corporate Transparency Act

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The U.S. Supreme Court issued an order on January 23, 2025, which provisionally reinstates the Corporate Transparency Act (CTA) while a legal challenge to it continues. This brief order, which stayed an injunction against the...more

Farella Braun + Martel LLP

What’s Ahead as Corporate Transparency Act Comes to a Crossroads

The recent whiplash regarding the validity of the Corporate Transparency Act (CTA)—it was enjoined just to particular parties, then enjoined nationwide, then un-enjoined, then enjoined again, while other courts let it...more

Lerman Senter PLLC

Fifth Circuit Reinstates Stay on Ownership Reporting - Deadline Lifted

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On December 26, 2024, the Fifth Circuit reinstated a stay of the Corporate Transparency Act’s requirement that businesses must file Beneficial Ownership Information reports. Accordingly, there is at present no obligation to...more

Neal, Gerber & Eisenberg LLP

CTA Update: DOJ Files SCOTUS Application to Stay Injunction

On December 26, 2024, a merits panel of the U.S. Court of Appeals for the Fifth Circuit reinstated a nationwide injunction against enforcement of the Corporate Transparency Act (CTA) that had been entered by the United States...more

Parker Poe Adams & Bernstein LLP

Corporate Transparency Act Filings Are Back on Hold

In an unusual turn of events, the Fifth Circuit Court of Appeals has reversed itself and put the Corporate Transparency Act (CTA) back on hold....more

Venable LLP

Fifth Circuit Reimposes Nationwide Preliminary Injunction

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After a rollercoaster ride last week, the Corporate Transparency Act's (CTA) nationwide preliminary injunction remains in place for the immediate future, pending further review by the U.S. Court of Appeals for the Fifth...more

Tucker Arensberg, P.C.

UPDATE: Corporate Transparency Act  (“CTA”) Enforcement Once Again On Hold

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As of December 26, 2024, the nationwide injunction that had been lifted only days ago has been put back in effect. This means that reporting requirements under the Corporate Transparency Act may not be enforced for the time...more

BakerHostetler

Nationwide CTA Injunction Is Back in Effect. What Happens Now?

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In yet another twist, the CTA is again currently enjoined (for now). On Dec. 26, in a highly unusual chain of events, the merits panel of the Fifth Circuit Court of Appeals vacated the emergency stay granted by the motions...more

Miller Canfield

Fifth Circuit Stays the Texas Federal District Court’s Nationwide Preliminary Injunction and Stay of the Corporate Transparency...

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On December 23, 2024, in Texas Top Cop Shop, Inc. v. Merrick Garland, Civil Action No.4:24-CV-478 (5th Cir. 2024), the Fifth Circuit Court of Appeals lifted a nationwide preliminary injunction and stay of the U.S. Corporate...more

Holland & Knight LLP

Corporate Transparency Act Back in Effect, But with Extended Deadlines

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High drama in Corporate Transparency Act (CTA) world: The latest saga involving the CTA commenced with the case of Texas Top Cop Shop, Inc., et al. v. Garland, et al., where a federal district court judge for the U.S....more

Genova Burns LLC

Corporate Transparency Act (CTA) - Reporting Requirements Revived

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The Corporate Transparency Act (CTA), which went into effect on January 1, 2024, mandates that almost all LLC owners submit annual beneficial ownership reports (BOI) to the Financial Crimes Enforcement Network (FinCEN). ...more

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