Last month, the SEC issued a No Action Letter interpreting Rule 506(c) that effectively provides a streamlined path for private fund sponsors to conduct an exempt general solicitation offering pursuant to Regulation D of the Securities Act of 1933. The guidance...
FinCEN Narrows CTA Reporting Requirements On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule to significantly narrow the applicability of the Corporate Transparency Act (CTA) reporting rule to apply solely to foreign...
Starting July 1, 2025, the OTC Markets Group will introduce OTCID Basic Market, replacing the current Pink Current tier. The OTC believes that this change will enhance transparency and provide investors with clearer insights into the level of disclosure and engagement...
Background In 2023, the New York County Manhattan District Attorney’s Antiquities Trafficking Unit, or NYATU, had seized a statue in the collection of the Cleveland Museum of Art for repatriation to the Republic of Türkiye. CMA acquired the 2nd-century headless statue...
On March 2, 2025, the U.S. Department of Treasury threw a new twist into the ongoing Corporate Transparency Act (CTA) enforcement saga by announcing that it will not enforce any fines or penalties against any U.S. citizens or domestic reporting companies that fail to...
Strengthening Board Control OpenAI is exploring governance changes that would grant its nonprofit board enhanced voting rights to prevent a hostile takeover by Elon Musk. This move follows Musk’s $97.4 billion bid, which was rejected by OpenAI’s board, and his legal...
Beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect. In the latest in a line of dizzying decisions surrounding the CTA, in Smith v. U.S. Department of the Treasury, the U.S. District...
On February 10, 2025, President Donald J. Trump signed an Executive Order pausing enforcement actions under the Foreign Corrupt Practices Act (FCPA), citing concerns that excessive enforcement was harming American businesses and national security interests. The order...
On January 23, 2025, the U.S. Supreme Court stayed a nationwide preliminary injunction issued in Texas Top Cop Shop, Inc. et al. v. Garland et al., creating further legal uncertainty surrounding the Corporate Transparency Act (CTA). Despite this ruling, the Financial...
On November 22, 2024, NFL star Baker Mayfield, his wife Emily Mayfield, and their business entity Team BRM, LLC (collectively, “Plaintiffs”), filed a lawsuit in the United States District Court, Western District of Texas, against several businesses owned or operated...