Asia Pacific (APAC) countries continue to “stagnate” in their rankings in 2023, only minimally above the global average, with most well below, according to two anti-corruption due diligence tools, TRACE’s 2023 Bribery Risk Matrix (TRACE Matrix) and Transparency International’s 2023
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Latest from Steptoe LLP - Page 13
UK NECC Publishes Amber Alert on Sanctions Evasion in the Art Storage Sector
The UK’s National Economic Crime Centre (“NECC”) recently issued an amber alert concerning the sanctions evasion, money laundering, and trafficking in cultural property risks presented to UK industries linked to artwork storage facilities and the art storage sector (the “Amber…
Industrial Policy Is Making a Comeback – With Some Investment Treaty Protections Standing in Its Way
On 18 January 2024, Steptoe and the British Institute of International and Comparative Law (BIICL) held a launch event for their joint empirical study on performance requirement prohibitions (PRPs) in international investment agreements (IIAs) (recording and publication available here).…
NAESB’s Development of a Standard Distribution Services Contract for DER Aggregators Selling State-Jurisdictional “Distribution Services” to Distribution Owners Raises Issues Similar to Order No. 2222
By Jennifer Key
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…
Potential new SAR-like Reporting Requirements for Certain U.S. Real Estate Transactions
By Jack Hayes & Jim Carolan
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
By Evan Abrams & Jack Hayes
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…