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Dec 10, 2024 | 
friedfrank.com | Michael T. Gershberg |Tobias Caspary |Neda Moussavi
Client memorandum | December 10, 2024 In 2025, a new outbound investment regime will take effect and require the notification, and in some instances the outright prohibition, of certain investments by U.S. persons in Chinese companies (including Hong Kong and Macau) that are engaged in specific activities related to semiconductors and microelectronics, quantum computing, and artificial intelligence (“AI”).
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Oct 28, 2024 | 
friedfrank.com | Michael T. Gershberg |Joseph P. Vitale
Authors: Michael T. Gershberg, Joseph P. VitaleAn important filing deadline under the Corporate Transparency Act (“CTA”) is on the horizon. While many companies have already been complying with the CTA since it took effect on January 1, 2024, the reporting deadline for companies formed prior to 2024 is January 1, 2025.
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Oct 28, 2024 | 
lexology.com | Michael T. Gershberg |Joseph P. Vitale
An important filing deadline under the Corporate Transparency Act (“CTA”) is on the horizon. While many companies have already been complying with the CTA since it took effect on January 1, 2024, the reporting deadline for companies formed prior to 2024 is January 1, 2025.
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Sep 24, 2024 | 
friedfrank.com | Michael T. Gershberg |Michael Sherman |Ashley Rodriguez
Client memorandum | September 24, 2024 Authors: Michael T. Gershberg (Washington, DC), Ashley Rodriguez (Washington, DC), Tyler Kaufman (New York)On September 4, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a final rule (the “Final Rule”) imposing certain anti-money laundering (“AML”) requirements under the Bank Secrecy Act (“BSA”) on certain SEC-registered investment advisers and exempt reporting advisers (“Covered Advisers”).
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Sep 12, 2024 | 
friedfrank.com | Michael T. Gershberg |Tobias Caspary |Neda Moussavi
On September 13, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) will publish an interim final rule extending its recordkeeping requirement from 5 to 10 years. This change had been anticipated and results from the recent extension of the statute of limitations for civil and criminal sanctions violations to 10 years. The new recordkeeping requirement takes effect in six months, on March 12, 2025.
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Sep 12, 2024 | 
lexology.com | Michael T. Gershberg |Tobias Caspary |Neda Moussavi
On September 13, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) will publish an interim final rule extending its recordkeeping requirement from 5 to 10 years. This change had been anticipated and results from the recent extension of the statute of limitations for civil and criminal sanctions violations to 10 years. The new recordkeeping requirement takes effect in six months, on March 12, 2025.
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Mar 14, 2024 | 
law360.com | Michael T. Gershberg |Michael Werner |Gregory Bernstein
ADVERTISEMENT Don't want ads? Subscribe or login now. By Michael Gershberg, Michael Werner and Gregory Bernstein (March 14, 2024, 7:01 PM EDT) -- On Feb. 16, the U.S. Department of the Treasury's Financial Crimes Enforcement Network issued a proposed rule that would impose a new reporting requirement for certain nonfinanced residential real estate transfers....
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Mar 14, 2024 | 
law360.co.uk | Michael T. Gershberg |Michael Werner |Gregory Bernstein
ADVERTISEMENT Don't want ads? Subscribe or login now. By Michael Gershberg, Michael Werner and Gregory Bernstein (March 14, 2024, 7:01 PM EDT) -- On Feb. 16, the U.S. Department of the Treasury's Financial Crimes Enforcement Network issued a proposed rule that would impose a new reporting requirement for certain nonfinanced residential real estate transfers....
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Feb 14, 2024 | 
lexology.com | Michael T. Gershberg |Gregory Bernstein
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) is set to issue a proposed rule that would impose a new reporting requirement for certain non-financed residential real estate transfers (“the Proposed Rule”). The rule is intended to improve transparency in an industry in which the U.S. government sees a high risk for money laundering activity by requiring reporting of such transactions, including disclosure of the beneficial owners of buyer entities.
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Oct 31, 2023 | 
lexology.com | Michael T. Gershberg |Gregory Bernstein
On January 1, 2024, the Beneficial Ownership Information Reporting Rule (“BOI Reporting Rule”) promulgated under the Corporate Transparency Act (“CTA”) will take effect. As discussed in previous alerts, the BOI Reporting Rule requires “reporting companies” to provide the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) with information about themselves and their beneficial owners.
