Introduction As part of their estate planning, individuals often utilize various legal entities, such as corporations, partnerships, limited liability companies, and trusts. In 2021, the federal Corporate Transparency Act (“CTA”) was enacted as part of a global effort to combat individuals’ use of entities to shield individual identities. Previously, the United States had resisted global […]
FinCEN Breaks Its Silence on the CTA
We previously reported on the requirements that many companies will need to address under the federal Corporate Transparency Act. Our earlier report indicated that “there are many unresolved issues under the CTA and the FinCEN rules” and that “hopefully, these issues will be addressed in future rulemaking, FAQs, or other interpretations, but so far that […]
Caveat Enhancer: The SEC’s Sweeping New Private Fund Adviser Rules
On August 23, 2023, the SEC announced that it had “adopted new rules and rule amendments to enhance the regulation of private fund advisers.” The new rules make sweeping changes to private fund advisers and the funds they manage and need to be carefully reviewed and taken seriously. The new rules require private fund advisers […]
Gov. Ron DeSantis Activates the Florida Small Business Emergency Bridge Loan Program
TALLAHASSEE, Fla. — Today, Governor Ron DeSantis activated the Florida Small Business Emergency Bridge Loan Program, making $20 million available for businesses impacted by Hurricane Idalia. Florida small business owners in need of assistance are encouraged to visit www.FloridaJobs.org/EBL to apply for the Florida Small Business Emergency Bridge Loan Program. Businesses in the following counties, including sole […]
Health Information Blocking Enforcement Begins September 1, 2023
On July 3, 2023, the U.S. Department of Health and Human Services (HHS) Office of the Inspector General (OIG) published its final rule implementing the provisions of Title IV of the 21st Century Cures Act (Cures Act) which authorize OIG to investigate claims of health information blocking and impose civil monetary penalties (CMP) for violations. […]
Seeing through the Transparency Act
Congress passed the Corporate Transparency Act, or CTA, in 2021 as part of a global effort to prevent individuals from using legal entities to shield their identities. For many years, the United States has been viewed as a significant holdout where individuals could hide behind entities, thereby facilitating money laundering and other financial crimes. The […]
Bad News and Good News – The SEC’s Cybersecurity Disclosure Rules
On July 26, 2023, the SEC announced that it had adopted new rules requiring issuers to disclose “material cybersecurity incidents” and “material information regarding…cybersecurity risk management, strategy, and governance.” As proposed, the rules included several components that received strong negative comments. For example: Given the current composition of the SEC, many observers expected the worst […]
USCIS To Publish Revised Form I-9
On August 1, 2023, U.S. Citizenship and Immigration Services will publish a revised version of Form I-9, Employment Eligibility Verification. Among the improvements to the form is a checkbox employers enrolled in E-Verify can use to indicate they remotely examined identity and employment authorization documents under an alternative procedure authorized by the Department of Homeland […]
The DOJ Speaks: Updated Guidance Regarding Corporate Information Governance as It Relates to Communication Platforms and Personal Devices
The U.S. Department of Justice (DOJ) recently announced updates to guidance related to corporate compliance programs. This expanded guidance instructs prosecutors to consider how compensation structures can drive compliance, including the use of financial penalties such as compensation clawback provisions to disincentivize non-compliance. The updated guidance further details how prosecutors should evaluate a company’s policies […]
AHCA Releases New Standards for When Face Masks Can be Required in Health Care Settings
In light of the end of the public health emergency, the Agency for Health Care Administration (AHCA) and Florida Department of Health (DOH) have jointly developed standards that provide the dos and don’ts of face mask mandates in health care settings. The new standards describe under what circumstances a health care provider can require a […]
