As of our last client update on the Corporate Transparency Act (CTA) litigation (see CTA client alert), the U.S. Supreme Court, in an 8-1 ruling, lifted a nationwide injunction issued by a Texas trial court in Texas Top
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U.S. Supreme Court Lifts Initial Injunction Against Enforcement Of Corporate Transparency Act, But A Separate Injunction Continues To Halt Implementation
The long and winding road of the Corporate Transparency Act (CTA) litigation (as discussed in our most recent CTA client alert) has taken another turn, and this time companies are driving blind. On New Year’s Eve, the U.S.…
Whistleblowing in Focus: Recent Developments, Emerging Issues, and Considerations for Companies. Part Three: Looking Ahead
An Active Year in Enforcement, with Changes to Come
The following is part of our annual publication Selected Issues for Boards of Directors in 2025. Explore all topics or download the PDF.
The Securities and Exchange Commission (SEC) and Department of Justice (DOJ) both had active enforcement years in…
Whistleblowing in Focus: Recent Developments, Emerging Issues, and Considerations for Companies. Part Two: Global Developments
Introduction
In this three-part series, we discuss recent developments relating to whistleblower programs in the United States. Second, we review whistleblower initiatives in other jurisdictions over the past year. Third, we consider emerging issues and considerations for companies in relation…
Whistleblowing in Focus: Recent Developments, Emerging Issues, and Considerations for Companies. Part One: Developments in the U.S.
Introduction
Whistleblower programs have proliferated and been growing in importance in the criminal and regulatory enforcement landscape globally. In this three-part series, we first discuss recent developments in whistleblower programs in the United States. Second, we review whistleblower initiatives in…
SEC Adopts Rules Requiring Daily Computation of Customer and PAB Reserve Requirements for Certain Broker-Dealers
On December 20, 2024, the Securities and Exchange Commission (the “SEC”) adopted amendments to Exchange Act Rule 15c3-3 (the “Customer Protection Rule”) to require carrying broker-dealers with $500 million or more in average total credits to perform the customer and…
Fifth Circuit Reinstates CTA Injunction Pending Oral Arguments in March; FinCEN January 13 Deadline on Hold
On December 26, the U.S. Court of Appeals for the Fifth Circuit vacated the previous grant of a stay of the injunction enjoining enforcement of the Corporate Transparency Act (CTA) and beneficial ownership reporting rule. As a result, the nationwide preliminary injunction…
Fifth Circuit Pauses District Court CTA Injunction; FinCEN Extends Filing Deadline to January 13, 2025
DOJ Appeals CTA Injunction; FinCEN Suspends Filing Requirement
As outlined in our prior update, on December 3, 2024, a Texas federal district court issued a preliminary injunction that temporarily blocks the Corporate Transparency Act (CTA) and its implementing regulations from taking effect nationwide. …