On February 7, 2024, at the request of the U.S. Department of Energy (DOE), NAESB held a kick-off meeting for the development of a standard model contract to facilitate purchases by distribution owners of “distribution services” from DER aggregators. The
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Potential new SAR-like Reporting Requirements for Certain U.S. Real Estate Transactions
On February 8, 2024, the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (2024 NPRM) about Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) regulations concerning persons involved in…
Commerce Proposes Significant New Regulations on AI Training and IaaS Providers
In a recent proposed rule, the Department of Commerce has taken additional steps toward imposing significant regulations on infrastructure as a service (IaaS) providers, including providers engaged in training certain large AI models. The notice of proposed rulemaking (NPRM…
Disappearing No More: Maintaining Electronic Messages for Antitrust Investigations
The Antitrust Division of the Department of Justice and the Federal Trade Commission recently issued a revised model second request clarifying that companies under investigation have an obligation to preserve communications on messaging platforms including those on so-called ephemeral applications. …
BIS Makes Further Changes to Administrative Enforcement, But Questions Remain
On January 16, 2024, the Assistant Secretary for Export Enforcement at the Department of Commerce’s Bureau of Industry and Security (BIS) issued a memorandum, announcing that:
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Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act Are Now In Effect
As of January 1, 2024, the Corporate Transparency Act (CTA) is effective, impacting millions of entities. On September 30, 2022, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published a final rule to implement the beneficial ownership…
The FTC Updates Size of Transaction Thresholds and Filing Fees for Premerger Notification Filings for 2024
The Federal Trade Commission (“FTC”) has announced updated size-of-transaction thresholds for premerger notification (Hart-Scott-Rodino or “HSR”) filings, as well as updates to the HSR filing fees and transaction value categories. Separately, the FTC has also updated the de minimis thresholds…
New York Enacts Prohibition Against Employers Collecting Employee Communications from Personal Accounts
Amid the reporting of the newest round of settlements by broker-dealers and financial advisers in late September for employee engagement in off-line business communications, last month also saw New York Governor Kathy Hochul sign legislation (A.836) prohibiting employers from requesting…
What Does the BTC ETP Approval Mean for the SEC’s Regulatory Approach to Crypto? Five Observations on the Immediate, Near Term, and Post-2024 Impact
On January 10, 2024, the Securities and Exchange Commission (“SEC” or the “Commission”) approved the listing and trading of eleven spot bitcoin exchange traded products (“ETPs”). [1] The Commission declared effective the registration statements for ten of the ETPs on…
The Top Ten Asia-Pacific FCPA Enforcement Actions of 2023
Please check out our most recent publication in our International Compliance Blog.