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U.S. Treasury Corporate Counsel

Foley & Lardner LLP

What U.S. Businesses Need to Know About Reentering the Syrian Market & the Changing Post-Assad Sanction Landscape

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On May 23, 2025, approximately five months after the Assad regime was overthrown, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) officially issued Syria General License (GL) 25, which lifted the...more

ArentFox Schiff

So Long Syria Sanctions? Not So Fast!

ArentFox Schiff on

On May 23, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 25, “Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain...more

Holtzman Vogel Baran Torchinsky & Josefiak

In-Compliance: Holtzman Vogel's March 2025 Round-Up

In Compliance: Holtzman Vogel's Monthly Round-Up In this March 2025 issue of In Compliance, we cover the following topics: President Trump Issues Executive Order on Election Integrity - Treasury Department Eliminates...more

Troutman Pepper Locke

OFAC Recordkeeping Requirement Extended to 10 Years

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On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule extending the recordkeeping requirements under OFAC’s regulations from five years to 10 years. This change...more

Ropes & Gray LLP

FinCEN Significantly Narrows Corporate Transparency Act Reporting Requirements

Ropes & Gray LLP on

On March 21, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) published an interim final rule (the “March 21 Rule”) that: Narrows (significantly) the beneficial ownership information (“BOI”)...more

Vinson & Elkins LLP

FinCEN and the U.S. Treasury Department Suspend CTA Enforcement – Forthcoming Rule to Narrow CTA Compliance to Foreign Reporting...

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On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced a suspension of enforcement actions related to the Corporate Transparency Act (“CTA”). This announcement means that reporting companies are...more

UB Greensfelder LLP

What the Latest Reinstatement of the Corporate Transparency Act Means

UB Greensfelder LLP on

Filing requirements under the Corporate Transparency Act (CTA) have been reinstated. Per FinCEN’s (Financial Crimes Enforcement Network’s) most recent Alert released on February 18, 2025, the new deadline for filing...more

Pierce Atwood LLP

It Lives: Trump Administration Defends Corporate Transparency Act; May Modify its Application

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On February 5, 2025, the Trump administration added a new chapter to the saga that has been implementation of the Corporate Transparency Act (CTA), filing a notice of appeal and motion for stay against an Eastern District of...more

Troutman Pepper Locke

Treasury and IRS Issue Updated Domestic Content Guidance Under IRA and First Updated Elective Safe Harbor

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On January 16, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2025-08 (Notice), which provides an updated safe harbor (First Updated Elective Safe Harbor) that modifies and otherwise...more

Miller Canfield

Trump Administration Opens the Door to Double-Tax-Rate Penalty on Foreign Companies and Individuals

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As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more

Vinson & Elkins LLP

Citing Loper, Fifth Circuit Declines Agency Deference, Overturns Sanctions Against Cryptocurrency Software

Vinson & Elkins LLP on

On November 26, 2024, the Fifth Circuit issued an opinion in Van Loon v. Department of the Treasury that invalidated economic sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on...more

Fenwick & West LLP

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

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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

Hogan Lovells

U.S. Treasury expands the scope of CFIUS investigative authority and updates civil monetary penalties

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On November 26, 2024, the U.S. Department of the Treasury (“Treasury”) issued a new final rule (the “Final Rule”) expanding the Committee on Foreign Investment in the United States’ (“CFIUS”) authority in three key areas...more

Venable LLP

A Stronger CFIUS: Final Rules Issued Expanding Mitigation and Enforcement Powers

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On November 18, 2024, the U.S. Department of the Treasury issued a final rule enhancing the mitigation monitoring and enforcement tools of the Committee on Foreign Investment in the United States (CFIUS or the "Committee")....more

BCLP

Corporate Transparency Act: Ongoing Litigation Not Likely to Change End-of-Year Filing Dates

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After the U.S. Congress enacted the federal Corporate Transparency Act (the “CTA”) on January 1, 2021, a wide range of plaintiffs immediately brought suit against the government challenging its constitutionality. Currently,...more

WilmerHale

Biden Administration Finalizes Controls on U.S. Investment in China

WilmerHale on

On October 28, the Biden Administration released its long-awaited final rule to restrict U.S. investment in China. This outbound investment regime, which is effective January 2, 2025, will impact all U.S. companies and...more

Epstein Becker & Green

Mental Health Parity: Federal Departments of Labor, Treasury, and Health Release Landmark Regulations

Epstein Becker & Green on

On September 9, 2024, the three federal departments responsible for regulating the health care benefits for more than 175 million Americans with private health insurance issued a final rule (the “Final Rule”) implementing...more

Jones Day

U.S. Tax Court Invokes Loper Bright for the First Time

Jones Day on

The U.S. Tax Court allows a dividend-received deduction ("DRD") for a Section 78 gross-up while also disallowing foreign tax credits in its first application of Loper Bright....more

Torres Trade Law, PLLC

Treasury Releases CFIUS 2023 Annual Report

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On July 23, 2024, the Committee on Foreign Investment in the United States (“CFIUS” or “the Committee”) released its annual report to Congress regarding the Committee’s national security reviews and investigations of certain...more

Paul Hastings LLP

U.S. Government Issues Proposed Rules in Significant Step to Restrict Outbound U.S. Investment in Chinese Technology

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On June 21, 2024, the Treasury Department released long-expected proposed regulations to curtail investments by U.S. persons (including investments by U.S. limited partners in non-U.S. pooled funds) and U.S.-controlled...more

Holland & Knight LLP

CTA Heats Up with New FAQs, Government and Amicus Briefs and New Draft Legislation

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The Corporate Transparency Act (CTA) is the gift that keeps giving. As affected entities and their advisers struggle to determine whether they are subject to the beneficial ownership information (BOI) reporting provisions of...more

Morrison & Foerster LLP

War Aid and Sanctions: National Security Act Includes Significant New Sanctions Authorities

On April 24, 2024, President Biden signed into law a long-debated $98 billion foreign aid and national security legislative package (the “Act”) providing funds for Israel, Taiwan, and Ukraine, and authorizing new sanctions...more

Morrison & Foerster LLP

OFAC Issues Omnibus Accounts Enforcement Case Involving Russia and Other Sanctions Programs

On March 14, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its first enforcement case of the year and its first ever involving dealings with a Russian designated for sanctions...more

Morrison & Foerster LLP

OFAC Year in Review 2023 – Part 1

2023 was another record year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Most prominently, OFAC continued to impose significant additional sanctions on Russia in...more

A&O Shearman

U.S. Imposes New Russia Sanctions and Export Controls and Warns of Risk of Continued Business with Russia

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On February 23, 2024, the United States imposed its largest number of new sanctions and export control designations against Russia to date—targeting over 600 individuals and entities across a wide swath of the Russian economy...more

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