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Insight

UPDATE: DOJ Issues Bulk Sensitive Data Rule Guidance, Requirements Go into Effect: What Companies Need to Know

by Matthew E.S. Coleman, Nicholas Farnsworth, Benjamin Hutten, Jeanine P. McGuinness, Shannon Yavorsky and Cosmas Robless
3 minute read | May.14.2025

We share what companies need to know about data handling practices and transactions that may fall within the DSP’s scope, plus a list of resources.

Insight

Trump Administration’s Sweeping Reciprocal Tariffs – What Companies Need to Know

by Harry Clark, Jeanine P. McGuinness, Elizabeth Zane, Maria Sergeyeva, Gregory I. Hume and Allison Lofgren Bradham
5 minute read | April.04.2025

Companies’ exposure resulting from the new tariffs will depend on the country of origin, value, and tariff classification of their imports.

Insight

Updated Beneficial Ownership Reporting Rules: All U.S. Companies Are Exempt; Only Foreign Companies Must Report

by Benjamin Hutten, Jeanine P. McGuinness, Scott Porter and Maria Sergeyeva
3 minute read | March.24.2025

ESG: Environmental, Social & Corporate Governance

Under FinCEN’s new interim final rule only foreign entities registered to do business in the U.S. are required to file BOI reports.

Insight

FinCEN Pauses Beneficial Ownership Reporting Enforcement: New Rule and Deadlines Coming by March 21, 2025

by Jeanine P. McGuinness, Benjamin Hutten, Scott Porter and Maria Sergeyeva
2 minute read | February.28.2025

Until the new rule takes effect and its deadlines pass, FinCEN will not impose fines or penalties on companies that fail to file or update BOI ...

Insight

White House to Expand Restrictions on Chinese Investment While Streamlining Investment Reviews for Allies

by Harry Clark, Jeanine P. McGuinness, Elizabeth Zane, Allison Lofgren Bradham, Maria Sergeyeva and Gregory I. Hume
3 minute read | February.24.2025

A Presidential Memorandum on “America First Investment Policy” announces planned changes to CFIUS investment review/outbound investment restrictions.

Insight

New Duties on Imports from Canada, Mexico and China – What Companies Need to Know – Update

by Harry Clark, Jeanine P. McGuinness, Elizabeth Zane, Gregory I. Hume, Maria Sergeyeva, Evgeniya Shakina and Allison Lofgren Bradham
4 minute read | February.04.2025

New duties authorized under IEEPA target goods that originated in Canada, Mexico, and China, prompting each country to announce retaliatory actions.

Insight

Corporate Transparency Act Beneficial Reporting Still on Hold Nationwide – Stay Tuned

2 minute read | January.27.2025

A nationwide stay of the CTA issued by a district court in Texas on January 7, 2025, remains in place.

Insight

U.S. Data Localization Law Coming Soon: DOJ Issues Final Rule on Certain Data Transfers to “Countries of Concern”

by Harry Clark, Benjamin Hutten, Thora Johnson, Jeanine P. McGuinness, Shannon Yavorsky, Elizabeth Zane, James Chou, Olivia Rauh and Cosmas Robless
10 minute read | January.17.2025

The DOJ has finalized prohibitions and restrictions on cross-border transfers of certain data to China and other “Countries of Concern.”

Insight

Corporate Transparency Act on Hold (Again), Pending Further Litigation

2 minute read | December.27.2024

The Corporate Transparency Act (CTA) is once again enjoined nationwide, and the CTA’s requirements to file reports of beneficial ownership are again ...

Insight

Corporate Transparency Act On Hold Nationwide

by Benjamin Hutten, Robert Loeb, Cesar Lopez-Morales, Jeanine P. McGuinness, Scott Porter and Maria Sergeyeva
2 minute read | December.06.2024

We expect FinCEN to clarify the impact of the court’s order soon, but it may take time to determine the CTA’s fate.

Insight

Financial Institutions Face Greater Export Controls Compliance Risk Under New BIS Guidance

by Harry Clark, Jeanine P. McGuinness, Elizabeth Zane, Benjamin Hutten and Maria Sergeyeva
6 minute read | November.11.2024

Both U.S. and non-U.S. financial institutions should evaluate and consider bolstering their transaction screening and export controls compliance.

Insight

Treasury Publishes Final Outbound Investment Restrictions With Focus on Tech Sector and China

by Harry Clark, Jeanine P. McGuinness, Elizabeth Zane, Gregory I. Hume and Evgeniya Shakina
13 minute read | November.05.2024

The Treasury Department issued a final rule prohibiting certain outbound investments by U.S. persons in Chinese and China-related tech companies.