On April 15, 2025, the Trump Administration issued an Executive Order titled “Restoring Common Sense to Federal Procurement” that seeks to reform the Federal Acquisition Regulation (“FAR”) and agency-specific supplements to contain only those “provisions required by statute or essential to sound procurement.” Along with a supplemental fact sheet, the Executive Order states that
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Europe Steps Up as U.S. Pauses FCPA Enforcement: What Companies Need to Know About the New International Anti-Corruption Taskforce
In a significant move signaling Europe’s growing autonomy in global anti-corruption enforcement, prosecutors from the United Kingdom, France, and Switzerland have formed a new cross-border alliance: the International Anti-Corruption Prosecutorial Taskforce. Announced on March 20, 2025 by the U.K.’s Serious Fraud Office (SFO), the taskforce is designed to deepen cooperation among these three countries on…
FinCEN Narrows Focus on Southwest Border
In the last few weeks, the Financial Crimes Enforcement Network (FinCEN) has circulated several instructions focusing on money services businesses operating in the southwest United States, answering the current Administration’s call for increased security measures in that area.
On March 11, FinCEN issued a Geographic Targeting Order (GTO) adding more requirements to certain money services…
Treasury Department Formally Exempts U.S. Companies from CTA
The guidance U.S. companies have been waiting for after years of ups and downs is finally here. In line with our last update, on March 21, 2025, FinCEN issued an interim final rule exempting U.S. companies and persons from the requirement to report, modify, or correct beneficial ownership information under the Corporate Transparency Act…
Treasury Department Declares Intent to Limit CTA to Foreign Reporting Companies
After the Financial Crimes Enforcement Network (FinCEN) stated that it would hold off on taking enforcement actions against Reporting Companies for failure to comply with the March 21, 2025, deadline under the Corporate Transparency Act (CTA), the U.S. Department of the Treasury announced its own intention to limit CTA enforcement to foreign companies.…
FinCEN’s March 21 CTA Deadline to Report Beneficial Ownership Info Will Not Be Enforced … Yet
The Financial Crimes Enforcement Network (FinCEN) published new guidance on Feb. 27, 2025, putting its plan to begin enforcing the Corporate Transparency Act (CTA) on hold. After the Feb. 17 order by the U.S. District Court for the Eastern District of Texas in Smith v. United States Department of Treasury made the CTA once again…
Texas Court Stays Nationwide Injunction Staying the CTA, Deadline to Report Beneficial Ownership Information is March 21, 2025
In our last update, we reported that despite the Supreme Court staying the nationwide injunction against FinCEN’s enforcement of the CTA in one Texas case, a nationwide stay of the Reporting Rule granted by a federal judge in the Eastern District in Smith v. United States Department of Treasury (6:24-cv-00336) remained in effect. …
Practical Tips for Companies Following President Trump’s Pause on FCPA Enforcement
Major Shift on Foreign Corrupt Practices Act: Trump Signs EO Pausing Enforcement
Last night, in a move with wide-ranging implications for American companies doing business abroad, President Trump issued an executive order (Order) temporarily halting enforcement of the Foreign Corrupt Practices Act (FCPA). The Order directs Attorney General (AG) Pam Bondi to review guidelines and policies governing FCPA investigations and enforcement actions in the next 180 days,…
Trump Tariffs on Canada, Mexico, and China
On February 1, 2025, the Trump Administration imposed long-expected tariffs on imports from Canada, Mexico, and China through the issuance of three executive orders (“EOs”). While some recent reporting suggested that implementation of these tariffs may be delayed to March 1, 2025, the White House confirmed on January 31, 2025 that these tariffs…