News & Analysis as of

Recordkeeping Requirements Penalties

Proskauer Rose LLP

SEC Cites Falsified Compliance Records in Two Recent SEC Settlements with CCOs

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Two SEC enforcement actions from earlier this month, each including charges against a firm’s Chief Compliance Officer in their personal capacity, underscore the importance of maintaining accurate records and upholding...more

Whiteford

Client Alert: New York City Employers: Paid Prenatal Personal Care Leave Rules Now in Effect

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As of July 2, 2025, New York City’s new rules for paid prenatal personal care leave are in effect. With the first month of enforcement now behind us, it is critical for all employers with employees working in New York City to...more

Stankie Law

OFAC Fines Harman International $1.4 Million for Iran Sanctions Violations

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On July 8, 2025, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement with Harman International Industries, Inc. (“Harman”) for $1,454,145 to settle potential civil...more

Amundsen Davis LLC

Illinois Prevailing Wage Update: Failure to Timely File a Certified Payroll Means Individual Liability, Debarment, and Financial...

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The Illinois Prevailing Wage Act (IPWA) is a union-backed law that places enormous burdens on construction contractors, developers, property owners, and public bodies throughout Illinois. It’s extraordinarily confusing,...more

BakerHostetler

POWER (Act) to the People! Philadelphia Implements Stringent New Requirements for Employers

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On May 27, Philadelphia enacted the POWER Act, which introduces sweeping changes to the city’s labor laws. Several provisions stand out for their immediate impact on Philadelphia employers....more

Burr & Forman

How Employers Can Prepare for I-9 Audits

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Employers across the United States are legally required to ensure their workforce is authorized to work in the country. Form I-9, officially known as the Employment Eligibility Verification form, is a critical part of this...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Acting Chair Caroline D. Pham Announces CFTC’s 30-Day Enforcement Sprint

On February 25, 2025, the U.S. Commodity Futures Trading Commission (CFTC) released an enforcement advisory regarding the impact of self-reporting, cooperation and remediation in enforcement cases (the “Enforcement...more

Woods Rogers

Employers Must Pay Close Attention to Form I-9 Processing

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In today's legal landscape, compliance with immigration laws is crucial for businesses of all sizes. Employers have a legal obligation to verify the employment eligibility of their workers, and one essential aspect of this...more

BCLP

SEC Off-Channel Communications Enforcement Sweep Continues - Settlements by 12 Firms and Assessments of Over $63 Million in...

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On January 13, 2025, the U.S. Securities and Exchange Commission (the “SEC”) announced settled charges against twelve firms for recordkeeping failures related to off-channel communications – i.e., failure to maintain business...more

Perkins Coie

Illinois Pay Transparency Requirements Arrive

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New pay transparency requirements took effect January 1, 2025, in Illinois. Under amendments to the Illinois Equal Pay Act of 2003 (the Act), employers must now include in any job posting for covered roles the...more

A&O Shearman

SEC Enters Into Off-Channel Settlements With Twelve Additional Firms Prior To Leadership Turnover

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On January 13, 2025, one week before Chair Gary Gensler is expected to step down as Chair, the Securities and Exchange Commission (“SEC”) announced settlements with twelve additional regulated entities for alleged...more

Akin Gump Strauss Hauer & Feld LLP

“Under the Wire” E-Comms Settlements: More Confusion Than Closure

On January 13, 2025, the U.S. Securities and Exchange Commission announced settled enforcement actions with five registered investment advisers for failing to maintain and preserve internal electronic communications. These...more

Goodwin

Deadline Approaching for Reporting 2024 ISO Exercises and ESPP Share Transfers

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The Internal Revenue Code requires corporations to provide information statements to employees (including former employees) and information filings to the IRS regarding exercises of incentive stock options (ISOs) by employees...more

Cozen O'Connor

Updated ICE Fine Matrix for Form I-9 Violations

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On January 2, 2025, the most recent Form I-9 Fine Matrix outlining the costs for Form I-9 compliance violations was published in the Federal Register. After a government audit of an employer’s Forms I-9, Employment...more

Proskauer Rose LLP

Eight Enforcement Trends That Likely Will End Under a Trump SEC

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The Voting Record and Public Statements of the Commissioners Provide a Roadmap - There has been much speculation on what SEC enforcement will look like under a new administration, especially now that President-elect Donald...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Proposes Rules Prohibiting and Restricting Certain Data Transactions to Address National Security Concerns

The Department of Justice’s (DOJ) proposed rule implements President Biden’s Executive Order (EO) on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of...more

Seward & Kissel LLP

Continued SEC Enforcement Actions Relating to Off Channel Communications

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Who may be interested: Registered Investment Advisers, Registered Investment Companies, Compliance Staff - Quick Take: The SEC recently announced a number of additional enforcement actions relating to recordkeeping...more

Foley Hoag LLP

OFAC Publishes Both Interim Final Rule Extending Recordkeeping Requirements and Comment Request Regarding its Information...

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OFAC issued an interim final rule extending OFAC’s recordkeeping requirements from 5 years to 10 years, to comport with the corresponding statute of limitations extension. OFAC also published a request for public comment...more

King & Spalding

FinCEN’s Final Rule on Anti-Money Laundering for Residential Real Estate Transfers

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On August 29, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule under the Bank Secrecy Act (“BSA”) requiring certain persons involved in real estate closings and settlements to report and maintain...more

Harris Beach Murtha PLLC

What New York Employers Should Know about the Freelance Isn’t Free Act

New Yorkers utilizing freelance workers or independent contractors for work totaling $800 or more will soon need to comply with New York’s Freelance Isn’t Free Act (“FIFA”). The Act, which was signed into law by Governor...more

Vinson & Elkins LLP

The Very Timely PWA Requirements Finalized

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On June 18, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (T.D. 9998) (the “Final Regulations”) regarding compliance with the prevailing wage...more

Proskauer - Law and the Workplace

Effective July 1, 2024: Chicago Paid Leave and Paid Sick and Safe Leave Ordinance

Effective July 1, 2024, the Chicago Paid Leave and Paid Sick and Safe Leave Ordinance (“Ordinance”) will entitle eligible employees to accrue up to 40 hours of Paid Leave and up to 40 hours of Paid Sick Leave in a 12-month...more

Adams & Reese

New 2024 Florida Legislation Impacting Community Associations

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Florida has introduced new legislation and implemented changes to various regulations impacting community associations, many of which have either gone into effect or will go into effect beginning July 1, 2024. This...more

Mitratech Holdings, Inc

Ensuring I-9 Compliance for Reduced Risk in Healthcare Facilities

As the backbone of patient care, healthcare organizations must meet Form I-9 requirements. However, it can sometimes get lost in the hiring process. There are a lot of things happening at the same time during hiring!...more

Seward & Kissel LLP

SEC Settles Charges with Adviser for Recordkeeping Violations and Staff Lays Out Factors Considered in Determining What Penalties...

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Who may be interested: Investment Advisers, Broker-Dealers - Quick Take: The SEC settled charges against an investment adviser for widespread recordkeeping deficiencies related to the adviser’s failure to obtain, maintain...more

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