The Presumption of Innocence Podcast: Episode 50 - Hidden in Plain Sight: How Kleptocrats Exploit U.S. Financial Systems
Nonprofit Basics: International Grantmaking – Part 2 Income Tax Withholding Rules
Nonprofit Basics: International Grant Making - Part 1 Overview and Antiterrorism Rules
Is Edward Snowden a Whistleblower?
Financial institutions across the United States have grappled with compliance requirements under the Customer Identification Program (CIP) Rule for more than two decades. A new exemption, approved in June 2025, promises...more
In a significant move, on June 27, 2025 the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order granting banks and their subsidiaries an exemption from the Customer Identification...more
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
As difficult as it is to pass laws, especially potentially controversial laws, sunset provisions on national security legislation provide an opportunity to re-assess effectiveness, impacts on privacy, and opportunity costs. ...more
The recent showdown over renewal of certain provisions of the USA Patriot Act (often called simply the Patriot Act) and the subsequent enactment of the USA Freedom Act have raised a number of questions about the ongoing...more
Not long after striking down the National Security Agency’s telephone surveillance program in ACLU v. Clapper, the Second Circuit is asking the parties to assess whether recently passed federal legislation has rendered the...more
Section 215 of the Patriot Act expires today. Section 215 addresses the Federal Bureau of Investigation’s ability to gather business records. In 2006, after passage of amendments to the Patriot Act, the Bush administration...more
In This Issue: - Second Circuit Rules Patriot Act Does Not Authorize Bulk Metadata Collection; Congress Reconsiders Certain Patriot Act Authorities - SEC Issues Cybersecurity Guidance for Investment Companies...more
Fast approaching is the June 1 expiration of certain provisions of the Patriot Act, including § 215 (codified as 50 U.S.C § 1861), which is the basis for the National Security Agency’s (NSA) bulk telephone metadata collection...more
Whatever your opinion of Edward Snowden, the shockwaves from his leaks of classified material continue to roil all three branches of the federal government. The latest wave broke last week when the United States Court of...more
Earlier this month the Ninth Circuit Court of Appeals became the third federal appellate court this year to hear argument on the legality of the NSA’s bulk collection of telephone metadata....more