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Jones Day

Legal Questions for Your Sustainability Team #3

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This series of posts seeks to identify legal questions that can add definition and value to the good work that sustainability teams are doing. Our last post focused on whether the revenue used to evaluate the applicability...more

Katten Muchin Rosenman LLP

FINRA Aligns CAT Timestamp Requirements with SEC Relief and Extension to 2030

The Financial Industry Regulatory Authority (FINRA) is updating Rule 6860(a)(2) so that industry members who use time stamps more granular than nanoseconds must continue to truncate (rather than round) those time stamps at...more

Latham & Watkins LLP

FinCEN Postpones New AML Rule for Investment Advisers

Latham & Watkins LLP on

On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule concerning the Anti-Money Laundering/Countering...more

Beveridge & Diamond PC

Deadline Extended for Reporting PFAS in Products in Minnesota, Proposed Minnesota PFAS Reporting Rule under Administrative Review

Beveridge & Diamond PC on

Under Minnesota’s PFAS in products law, manufacturers of products containing intentionally added per- and polyfluoroalkyl substances (PFAS) must report those products to the Minnesota Pollution Control Agency (MPCA) by...more

Dickinson Wright

Ohio’s Cyber Law For Local Governments: 5 Steps Over 75 Days to Meet the September 29 Deadline

Dickinson Wright on

In its FY 2026 budget, Ohio quietly folded in a sweeping cybersecurity mandate that will require every “political subdivision” to have a cybersecurity program that aligns with recognized industry frameworks and adopt strict...more

A&O Shearman

FSB update on progress under 2021 roadmap on climate-related risks

A&O Shearman on

The Financial Stability Board (FSB) has published its 2025 progress report on the implementation of its 2021 Climate Roadmap. The report provides a factual overview of progress made across four key areas: disclosures, data,...more

Sheppard Mullin Richter & Hampton LLP

CFPB Withdraws Rule to Eliminate State Enforcement Notification Requirements

On July 21, the CFPB withdrew its plan to repeal rules that provide procedures for state officials to notify the Bureau before initiating enforcement actions under the Consumer Financial Protection Act (CFPA). The CFPB cited...more

Snell & Wilmer

Treasury and FinCEN Announce Delay of IA–AML Rule Implementation to January 1, 2028

Snell & Wilmer on

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the Anti‑Money Laundering/Countering the Financing of Terrorism...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Delays Effective Date of Investment Adviser Rule and Intends to Revisit the SEC Customer Identification Program Rule for...

In September 2024, FinCEN issued the Investment Adviser Rule, which aims to “address ongoing illicit finance risks, threats, and vulnerabilities posed by criminals and foreign adversaries that exploit the U.S. financial...more

Seward & Kissel LLP

FinCEN Postpones Investment Adviser AML Requirements, Buying Time for Revisions

Seward & Kissel LLP on

On July 21, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced that it was delaying the effective date of its final rule establishing Anti-Money Laundering/Countering the Financing...more

Bergeson & Campbell, P.C.

Minnesota Extends January 1, 2026, PFAS Reporting Deadline to July 1, 2026

The Minnesota Pollution Control Agency (MPCA) announced on July 23, 2025, that it will extend the January 1, 2026, deadline for reporting products containing intentionally added per- and polyfluoroalkyl substances (PFAS) to...more

Foley & Lardner LLP

Update: CMS Extends Skilled Nursing Facilities’ Medicare Revalidation Deadline

Foley & Lardner LLP on

On July 17, 2025, the Centers for Medicare and Medicaid Services (CMS) announced an additional extension of the deadline by which skilled nursing facilities (SNFs) must revalidate their Medicare enrollments. Enrolled SNFs...more

Bergeson & Campbell, P.C.

EPA Seeks Comment on New Plan to Track the Adoption of Bilingual End-Use Pesticide Labels

On July 21, 2025, the U.S. Environmental Protection Agency (EPA) released for comment a new proposed streamlined approach to track the adoption of bilingual labeling of pesticide products and provided updated guidance on...more

A&O Shearman

EC adopts Delegated Regulation to postpone ESRS disclosure requirements for wave one companies

A&O Shearman on

The European Commission has adopted a Delegated Regulation amending Delegated Regulation (EU) 2023/2772, introducing targeted amendments, referred as a "quick fix", to postpone the application of certain disclosure...more

Skadden, Arps, Slate, Meagher & Flom LLP

Reminder: Equity Reports for Pennsylvania Lobbyists and Lobbying Firms Due July 30

The annual equity report for all Pennsylvania lobbyists and lobbying firms is due July 30, 2025, as required by Act 70 of 2021. The filing must disclose either the total value or percentage of equity held by a lobbyist or...more

Ropes & Gray LLP

A CSRD Transposition Update – Three Additional Countries Adopt the “Stop the clock” delay

Ropes & Gray LLP on

Reporting obligations under the European Union’s Corporate Sustainability Reporting Directive are created under EU member state national legislation adopted pursuant to the CSRD. We have again updated our tracker to reflect...more

Jackson Lewis P.C.

Mid-Year 2025

Jackson Lewis P.C. on

The last six months have been a tumultuous time for employers. The pace and degree of change is creating new challenges — and ongoing uncertainty. Our Mid-Year 2025 report sifts through the volume of federal-level executive...more

Hone Maxwell

Understanding FATCA and Its Impact on Foreign Financial Institutions: Why Finding Financial Services as an American Abroad Can Be...

Hone Maxwell on

As an American living abroad, you may have experienced firsthand the challenges of finding a financial institution willing to work with you. Whether it’s for opening a bank account, investing in local markets, securing a...more

K&L Gates LLP

United States: AML Reprieve for Investment Advisers

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On July 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it is delaying the effective date of the investment adviser anti-money laundering rule (IA AML Rule) for two years from 1 January 2026 to 1...more

Arnall Golden Gregory LLP

SNF Off-Cycle CMS-855A Reporting Delayed to January 1, 2026

The Centers for Medicare & Medicaid Services (“CMS”) has extended the window for skilled nursing facilities (“SNFs”) to file off-cycle Medicare revalidation documents until January 1, 2026. This marks CMS’ third deadline...more

Troutman Pepper Locke

FUNDamentals – FinCEN Delays Investment Adviser AML Rule Until 2028, Signals Revisions to Scope

Troutman Pepper Locke on

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date of the final rule imposing anti-money laundering (AML) obligations on...more

Proskauer Rose LLP

A Securities and Exchange Commission (SEC) Analisará os Critérios de Elegibilidade para Emissores Privados Estrangeiros (Foreign...

Proskauer Rose LLP on

Empresas latino-americanas com valores mobiliários registrados nos Estados Unidos, ou que pretendem registrá-los, devem ficar atentas. A SEC (Comissão de Valores Mobiliários dos EUA) publicou um “concept release” propondo...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Mississippi Commission on Environmental Quality and Greenwood Soybean Processing/Oil Extraction Facility Enter...

The Mississippi Commission on Environmental Quality (“MCEQ”) and Oxbow Greenwood, LLC (“OG”) entered into a July 3rd Agreed Order 9 (“AO”) addressing alleged violations of an Air Permit. See Order No. 7520 25....more

Procopio, Cory, Hargreaves & Savitch LLP

When Must Private Fund Managers File as an Exempt Reporting Adviser in California?

Some private fund managers in California face potentially dire consequences if they fail to properly register with the state and the U.S. Securities and Exchange Commission (SEC). Failing to adhere to relevant securities laws...more

Sheppard Mullin Richter & Hampton LLP

China Initiates Mandatory Reporting Regime for Personal Information Protection Officers

On July 18, 2025, the Cyberspace Administration of China (the “CAC”) issued the Notice on Launching the Reporting Mechanism for Personal Information Protection Officers (the “Notice ”). This development marks a significant...more

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