News & Analysis as of

Regulatory Requirements Enforcement Actions Registration Requirement

Orrick, Herrington & Sutcliffe LLP

CPPA fines data broker for failing to register under the Delete Act

On July 28, the CPPA released a stipulated final order to impose a $55,400 administrative fine on a data broker for failing to register with the agency by the January 31, 2024, deadline as required by California’s Delete Act....more

Davis Wright Tremaine LLP

Contractor Registration in Washington State: Why It's an Important Prerequisite To File Breach of Contract Lawsuits

In Dobson v. Archibald, the Washington Supreme Court addressed and confirmed statutory analyses concerning the required contractor registration in Washington. 1 Wash. 3d 102, 523 P.3d 1190 (2023). Contractors and potential...more

McDermott Will & Schulte

CFTC Staff Letter 25-14: What Is a “U.S. Person”?

On May 21, 2025, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division and Division of Market Oversight jointly issued Staff Letter 25-14 in response to a request from SCB Limited, a Bahamas-based...more

Cadwalader, Wickersham & Taft LLP

Regulation in Flux, March 2025 - CFTC Staff Withdraws Advisory on Swap Execution Facility Registration Requirement

On March 13, 2025, the Commodities Futures Trading Commission (“CFTC”) issued Letter 25-05, withdrawing controversial and much-criticized Staff Letter 21-19 (“SEF Registration Advisory”), which was issued September 29, 2021...more

Kerr Russell

Registration and Fingerprinting Requirements for Foreign Nationals

Kerr Russell on

Beginning April 11, 2025, the U.S. Citizenship and Immigration Service will enforce provisions requiring all non-U.S. citizens over age 14 register and be fingerprinted if they are in the U.S. for at least 30 days and have...more

Carlton Fields

SEC Deep-Sixes Its Expanded “Dealer” Definition

Carlton Fields on

Last year, the Securities and Exchange Commission amended its definition of “dealer” to require broker-dealer registration by some persons or entities previously considered securities “traders” not subject to such...more

Paul Hastings LLP

DOJ Announces Significant Proposed Changes to Amend and Clarify FARA

Paul Hastings LLP on

On December 19, 2024, the Department of Justice (DOJ) published a Notice of Proposed Rulemaking (NPRM) intended to “update and clarify” the regulations under the Foreign Agents Registration Act (FARA). The proposed changes to...more

Ballard Spahr LLP

CPPA Announces Settlements with Data Brokers for Failure to Register Under the Delete Act

Ballard Spahr LLP on

On November 14, 2024, the California Privacy Protection Agency (“CPPA”), which is tasked with enforcing the California Consumer Privacy Act (the “CCPA”), announced it settled with two data brokers, Growbots, Inc. and UpLead...more

Proskauer - Blockchain and the Law

CFTC Issues Cease and Desist Order to Binary Options Operator Using Smart Contracts

On January 3, 2022, the Commodity Futures Trading Commission (the “CFTC”) entered an order charging Blockratize, Inc. (d/b/a Polymarket.com) (“Polymarket”) with offering off-exchange binary options contracts and failing to...more

Goodwin

10 Key Takeaways From California’s New Consumer Finance Regulatory And Enforcement Regime

Goodwin on

Three California laws that affect fintech companies will go into effect on January 1, 2021. The California Consumer Financial Protection Law (CCFPL) expands the scope of the Department of Business Oversight’s (DBO) current...more

Skadden, Arps, Slate, Meagher & Flom LLP

Department of Justice Announces First Known Criminal Prosecution Under the Lobbying Disclosure Act

On June 25, 2020, the Department of Justice (DOJ) announced that Jack Abramoff intends to plead guilty to criminal violations of the Lobbying Disclosure Act of 1995 (LDA), in what is the first known criminal prosecution under...more

Sheppard Mullin Richter & Hampton LLP

FinCEN – We Will Identify Where Compliance Is Not Taking Place And Take Appropriate Action

Last week we reported that FinCEN had issued new guidance addressing cryptocurrency and other convertible virtual currency. The need for compliance was reinforced this week. In a speech by Sigal Mandelker, Under Secretary for...more

Polsinelli

CFTC Staff No-Action Relief Allowing Additional Swap Activity for a Bank Relying on the IDI Exclusion from Swap Dealer...

Polsinelli on

On August 28, 2018, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) released a staff no-action letter allowing an anonymous individual financial institution...more

The Volkov Law Group

Beam Settles FCPA Violations with SEC for $8 Million for Pervasive Third-Party Bribery Schemes

The Volkov Law Group on

After a lengthy investigation conducted by the SEC, Beam Suntory agreed to pay $8 million to settle FCPA violations in India. Beam’s settlement took over 5 years from initial disclosure to resolution – a long-time to say the...more

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