News & Analysis as of

New Regulations U.S. Treasury

Orrick, Herrington & Sutcliffe LLP

Treasury revokes final rule following Congress’s repeal

On July 11, the IRS published a rule in the Federal Register revoking a rule the IRS had issued in December 2024 after the rule had been repealed by Congress under the Congressional Review Act. The final rule, “Gross Proceeds...more

Robinson Bradshaw

Application of New Anti-Money Laundering Regulations to Advisers to Private Funds

Robinson Bradshaw on

On Sept. 4, 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) published a final rule imposing new anti-money laundering (AML) and countering the financing of terrorism (CFT) requirements on...more

Hogan Lovells

UPDATE #2: Effective date of FinCEN’s Section 2313a orders against three Mexican financial institutions delayed until September 4

Hogan Lovells on

U.S. financial institutions that conduct funds transfers with the designated Mexican institutions have until 4 September to implement compliance procedures. Transfers of funds involving these designated Mexican institutions...more

Husch Blackwell LLP

New Executive Order Targets Wind and Solar Tax Credits

Husch Blackwell LLP on

On July 7, 2025, President Trump signed the executive order “Ending Market Distorting Subsidies for Unreliable, Foreign-Controlled Energy Sources.” The EO directs the Secretary of the Treasury to “strictly enforce” the...more

Seyfarth Shaw LLP

7 Key Changes to the Qualified Opportunity Zone Incentive Under the One Big Beautiful Bill Act

Seyfarth Shaw LLP on

On July 4, President Trump signed into law H.R. 1, the One Big Beautiful Bill Act (OBBBA), a sweeping 870-page piece of legislation that introduces significant changes across various areas of federal policy. While full...more

Morrison & Foerster LLP

No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more

Hogan Lovells

UPDATE: Effective date regarding FinCEN’s new Section 2313a Orders against three Mexican financial institutions

Hogan Lovells on

U.S. based financial institutions that conduct funds transfers with the designated Mexican institutions have until 21 July to implement compliance procedures. Transfers of funds involving these designated Mexican...more

Hogan Lovells

FinCEN invokes new Section 2313a authority against three Mexican financial institutions: The who, what, when, where, why, and...

Hogan Lovells on

The orders represent the first use of new authorities by FinCEN. U.S. based financial institutions that conduct funds transfers with the designated Mexican institutions will be subject to significant compliance obligations,...more

Cozen O'Connor

Stablecoins: Navigating the Money Transmitter Minefield & Forthcoming Federal Regulatory Frameworks

Cozen O'Connor on

As digital assets gain traction across financial markets, stablecoins—cryptocurrencies pegged to fiat currencies like the U.S. dollar—are emerging as a practical medium for capital contributions, settlements, and liquidity...more

K&L Gates LLP

Proposed Retaliatory US Taxes Would Impact Cross-Border Transactions

K&L Gates LLP on

Executive Summary - Retaliatory tax provisions contained in H.R. 1, the “One Big Beautiful Bill Act” that recently passed the US House of Representatives, if enacted, would drastically impact common cross-border transactions,...more

Morgan Lewis

The Future of Payments: US Stablecoin Legislation Takes Shape

Morgan Lewis on

The US Congress is advancing legislation to establish a regulatory framework for stablecoins, with the US Senate’s GENIUS Act of 2025 at the forefront. The bill outlines requirements for permitted issuers, redemption...more

Seward & Kissel LLP

Should you call 911 about Section 899?

Seward & Kissel LLP on

On May 22, 2025, the House of Representatives passed by a one-vote margin the “One Big Beautiful Bill Act” (the “House Bill”), which has now moved to the Senate for consideration. This Memorandum discusses the House Bill’s...more

Eversheds Sutherland (US) LLP

Senators oppose FinCEN’s Interim Final Rule on the Corporate Transparency Act

On May 27, 2025, Senators Sheldon Whitehouse (D-RI) and Charles E. Grassley (R-IA) submitted a comment to US Treasury Secretary Scott Bessent expressing strong opposition to the Financial Crime Enforcement Network’s Interim...more

Bass, Berry & Sims PLC

U.S. Government Eases Some Restrictions on Syria

On May 23, 2025, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) announced several actions to provide sanctions relief to Syria. OFAC is the primary government agency responsible for administering U.S....more

Baker Botts L.L.P.

U.S. Government Issues Broad Sanctions Relief for Syria

Baker Botts L.L.P. on

On May 23, 2025, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued Syria General License 25 (“GL 25”), effectively lifting U.S. sanctions on Syria. This move follows President Trump’s announcement on...more

McDermott Will & Emery

The Proposed US Tax Regime for Non-US Investors and Companies

McDermott Will & Emery on

On May 22, 2025, the US House of Representatives narrowly passed a sweeping $3.8 trillion tax reconciliation package known as the One Big Beautiful Bill Act. The legislation now moves to the US Senate, where significant...more

Fox Rothschild LLP

US Treasury Department Has Begun Enforcing New Outbound Investment Rules

Fox Rothschild LLP on

The U.S. Department of the Treasury has started enforcing final regulations that restrict, and in some cases prohibit, U.S. companies, funds and individuals from making certain investments in some technology industries owned...more

Hogan Lovells

U.S. Treasury announces fast track pilot program for foreign investment reviews

Hogan Lovells on

Key takeaways U.S. Treasury to establish a “fast track” foreign investment review process. It will include a “Known Investor” portal that allows the submission of information in advance of filing with Committee on Foreign...more

Cooley LLP

US Outbound Investment Enforcement Is Now Live

Cooley LLP on

Despite uncertainty amid talks of reforming the Outbound Investment Security Program (OISP), the US Department of the Treasury is already actively pursuing enforcement actions against transaction parties that may have...more

K&L Gates LLP

FinCEN's New Reporting Requirements for Nonfinanced Residential Real Estate Transactions

K&L Gates LLP on

Effective 1 December 2025, the Financial Crimes Enforcement Network (FinCEN) will implement comprehensive nationwide regulations aimed at increasing transparency and combating money laundering in the United States residential...more

Morgan Lewis

Treasury and IRS Promulgate Final Regulations Governing Resolution of Federal Tax Controversies by the Independent Office of...

Morgan Lewis on

The US Department of the Treasury and the Internal Revenue Service (IRS) have released Final Regulations related to the resolution of federal tax controversies by the Independent Office of Appeals (Appeals), largely rejecting...more

Troutman Pepper Locke

IRS Finalizes New Rules for DeFi Brokers: Challenge Immediately Filed in Texas Federal Court

Troutman Pepper Locke on

The U.S. Department of the Treasury and the Internal Revenue Service (IRS) released final regulations that significantly impact the reporting requirements for brokers involved in digital asset transactions. The stated aim of...more

Buchalter

The U.S. Finalizes Outbound Investment Restrictions on Technology Development

Buchalter on

Precedent-Setting Investment Restrictions – On January 2, 2025, the U.S. will start restricting foreign investments by U.S. persons in certain national security technologies. The Outbound Investment Rule and associated...more

Jones Day

Final Regulations Expand Access to "Direct Pay" Elections for Energy Credits

Jones Day on

The U.S. Department of the Treasury and the Internal Revenue Service have issued final regulations allowing tax-exempt entities that are partners in clean energy projects to elect to receive energy tax credits in cash....more

Fenwick & West LLP

Compliance Deadline Approaches for New Regs Targeting U.S. Investment in Chinese AI, Semiconductors, Quantum Tech

Fenwick & West LLP on

On November 15, the U.S. Department of the Treasury published final regulations to implement its long-awaited “Outbound Investment” Security Program, which the Biden Administration originally introduced in August 2023 under...more

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