On May 12, 2025, the Criminal Division of the Department of Justice (“DOJ”) announced several policy changes related to its approach to white collar criminal enforcement. Matthew R. Galeotti, the current head of the Criminal Division, noted that DOJ would be
Latest from Cleary Enforcement Watch
DOJ Issues Additional Guidance as Data Security Program Enters into Effect; Limits Enforcement for First 90 Days
On April 11, 2025, the U.S. Department of Justice, National Security Division (“DOJ”) issued a compliance guide (“Compliance Guide”), a set of frequently asked questions (“FAQs”), and a 90-day limited enforcement policy (“Enforcement Policy”) relating to implementation of the Data
U.S. Government Signals Intent to Increase Enforcement of U.S. Export Controls
Earlier this month, the U.S. Department of Commerce (Commerce), Bureau of Industry and Security (BIS) held its annual Update Conference on Export Controls and Policy (the Conference). During the Conference, key government officials signaled an intent to ramp up enforcement
New Anti-Corruption Taskforce Announced by Authorities in the UK, France, and Switzerland
On March 20, 2025, the United Kingdom’s Serious Fraud Office (“SFO”), France’s Parquet National Financier (“PNF”), and Switzerland’s Office of the Attorney General (“OAG”) signed a founding statement to establish a new International Anti-Corruption Prosecutorial Taskforce.[1] The new taskforce
FinCEN Eliminates CTA Requirements for All U.S. Companies and U.S. Individuals
As discussed in our last Corporate Transparent Act (CTA) update, the U.S. Treasury Department announced on March 2 that it planned to issue an interim rule excluding U.S. companies and citizens from CTA reporting obligations. The Financial Crimes Enforcement
SEC Staff Reverses Some “Gross/Net” Marketing Rule Guidance
On Wednesday evening, the SEC Staff published two new FAQs relating to the presentation of gross and net performance under the Investment Advisers Act Marketing Rule, the sweeping 2022 overhaul of the advertising and endorsement restrictions applicable to registered investment
Trump Administration Proposes Eliminating CTA Requirements for All U.S. Companies
We noted in our last Corporate Transparent Act (CTA) update that on February 27, 2025, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury Department, announced that it would not take any enforcement actions against any company
FinCEN Pauses All CTA Filing Obligations and Will Issue New Rules
Amid various ongoing litigation concerning the constitutionality of the Corporate Transparency Act (CTA), the U.S. Financial Crimes Enforcement Network (FinCEN) had announced on February 19, 2025, that it was extending the CTA beneficial ownership information filing deadline for most companies
Remaining Injunction Pausing Corporate Transparency Act is Lifted; FinCEN Extends General Filing Deadline to March 21; Statute’s Future Remains Uncertain
As previously reported (see CTA client alert), on January 23, 2025, in Texas Top Cop Shop v. Bondi, the U.S. Supreme Court stayed an injunction barring enforcement of the Corporate Transparency Act (CTA), but a different Texas trial
Consumer Protection Compliance Remains Crucial in Spite of CFPB Work Stoppage
For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit What to Expect From a Second Trump Administration.
The new administration has recently taken steps to reduce or even eliminate the