On April 7, the Federal Deposit Insurance Corporation (the “FDIC”) issued a notice of proposed rulemaking (the “FDIC NPR”)[1] to implement provisions of the “Guiding and Establishing National Innovation for U.S. Stablecoins Act” or the “GENIUS Act.”[2] The …

On September 19, 2025, the US Department of the Treasury (Treasury) issued an Advance Notice of Proposed Rulemaking (ANPRM), seeking public comment related to its implementation of the Guiding and Establishing National Innovation for US Stablecoins Act (the GENIUS Act), …

• What’s new: Senate Democrats have introduced a DeFi proposal that creates a new regulatory framework for decentralized finance platforms, focusing on preventing illicit finance and regulatory arbitrage by applying existing securities market requirements to DeFi.
• Why it matters: The DeFi

Guarantees of confidentiality and anonymity are important considerations for whistleblowers seeking to report information on violations to regulators and other public entities. These guarantees ensure the safety of whistleblowers when filing complaints, often against entities with substantial resources and some …

On November 18, 2024, the U.S. Department of the Treasury (“Treasury”) issued a final rule (the “Final Rule”) that amends the regulations administered and enforced by the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”).[1]…

In late October 2024, the U.S. Treasury Department (Treasury) issued its final rules (the Outbound Rules) implementing President Biden’s Executive Order (EO) 14105 on “outbound” U.S. investment. See our prior mailers here and here. The Outbound Rules will take …

It appears a new item must soon be added to the list of life’s certainties: “death, taxes and the CTA.”

Effective January 1, 2024, the Corporate Transparency Act (“CTA”) requires many entities to report information about their beneficial owners, senior …

On April 15, 2024, the secretary of the Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (CFIUS or Committee), published a notice of proposed rulemaking (Proposed Rule) to expand CFIUS’ investigation and …

On April 12, 2024, the U.S. Department of Treasury and the Internal Revenue Service published proposed regulations regarding the 1% excise tax on certain stock redemptions and economically similar transactions (corporate “repurchases”) by publicly traded U.S. corporations (“Covered Corporations”) on …

On February 13, the U.S. Treasury, Financial Crimes Enforcement Network (“FinCEN”) proposed¹ (the “Proposed Rule”) to apply affirmative anti-money laundering and countering-the-financing-of-terrorism (“AML/CFT”) program obligations as prescribed by the Bank Secrecy Act (the “BSA…

On November 3, 2023, the 10 voting members of the Financial Stability Oversight Council (“FSOC” or “Council”)[1] voted unanimously to finalize (1) amendments to its existing interpretive guidance (“2019 Interpretive Guidance”)[2] governing …

On September 19, 2023, the U.S. Department of the Treasury released nine principles for net-zero financing and investment by financial institutions.[1] The Principles focus on “scope 3” financed and facilitated greenhouse gas emissions (i.e., indirect emissions included …

On July 26, 2023, the U.S. Department of Justice’s National Security Division (“NSD”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a Tri-Seal …

Today we are taking decisive actions to protect the U.S. economy by strengthening public confidence in our banking system. This step will ensure that the U.S. banking system continues to perform its vital roles of protecting deposits and providing access …

On December 28, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued five new frequently asked questions (“FAQs”) that clarify the scope of Executive Order (“E.O.”) 13959, the basis for …