Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Matthew Orso

Photo of Matthew Orso Matt is co-chair of the Bank Defense & Counseling team for the Government Investigations and White Collar Litigation Department. He defends companies and individuals facing government investigations and helps them navigate these inquiries to resolution.

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At Long Last, FinCEN Issues Beneficial Ownership Information Reporting Rule

Financial Institution Regulation
At long last, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule establishing a beneficial ownership information reporting requirement for corporations and companies both large and small. In its announcement earlier today, FinCEN explained that the rule will require most companies and corporations registered to do business in the United States to report information about their… Continue Reading

Proposed Federal Rule Signals Remote Form I-9 Inspection of Employee Documents Will Likely Become Permanent Option

Immigration and Worksite Enforcement
On August 18, 2022, the Department of Homeland Security (DHS) published a Proposed Rule titled Optional Alternatives to the Physical Document Examination Associated With Employment Eligibility Verification (Form I-9). The Proposed Rule would formalize the authority of the Secretary of Homeland Security to extend certain COVID-19 rules permitting remote inspection of employee documents presented for… Continue Reading

FinCEN Encourages “Increased Vigilance” and Highlights Red Flags for Evasion of Russian Sanctions including Use of Virtual Currency

Anti-Money Laundering, Enforcement and Prosecution Policy and Trends, Financial Institution Regulation, Sanctions, Trade Embargo, and Export Controls
RELATED UPDATES: FinCEN Alert Highlights Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites and Their Proxies (January 30, 2023) New Revelations in Ukraine Lead to Tightening Global Sanctions (April 8, 2022) Western Companies Starting to Feel Impact of Russian Sanctions (March 24, 2022) The Financial Crimes Enforcement Network (FinCEN) has issued an alert… Continue Reading

U.S. Supreme Court Determines Action to Rescind DACA was Arbitrary and Capricious

Immigration and Worksite Enforcement
On June 18, 2020, the U.S. Supreme Court issued a long-awaited decision regarding the Department of Homeland Security’s (“DHS”) choice to rescind the immigration program Deferred Action for Childhood Arrivals (“DACA”). The Court noted the question before it was not whether DHS may rescind DACA but rather, whether DHS followed proper procedure in rescinding the… Continue Reading

Employer Update: DHS Extends Temporary Protected Status and Work Authorization for El Salvador, Haiti, Sudan, and Nicaragua

Immigration and Worksite Enforcement
The Department of Homeland Security (DHS) announced on March 1, 2019, an extension of the Temporary Protected Status (TPS) for qualifying individuals from El Salvador, Haiti, Sudan, and Nicaragua. DHS also announced a nine-month automatic extension of these TPS beneficiaries’ Employment Authorization Documents (EADs), allowing beneficiaries to work in the United States until January 2,… Continue Reading

H-1B Employers Face Increased Site Visits

Immigration and Worksite Enforcement
Employers using the H-1B visa program should take note as additional site visits may be on the horizon.  U.S. Citizenship and Immigration Services (“USCIS”), part of the Department of Homeland Security, recently announced a new targeted approach to detect H-1B visa fraud and abuse and increased site visits of H-1B employers. In selecting worksite visits,… Continue Reading

FinCEN Opens 2017 with SAR Sharing Guidance for Casinos

Anti-Money Laundering, Compliance
Financial institutions’ ability to share suspicious activity reports (“SARs”) within the corporate organizational structure serves as an important tool for Bank Secrecy Act compliance and risk avoidance.  FinCEN began 2017 by reminding casinos of their ability to share information under this rule. Subject to certain limitations, casinos may share with domestic parents and affiliates suspicious… Continue Reading

The Export/Immigration Dilemma: Don’t Let OSC Catch Your HR Department Unawares

Immigration and Worksite Enforcement, Sanctions, Trade Embargo, and Export Controls
On March 31, 2016, the U.S. Department of Justice’s Office of Special Counsel for Immigration-Related Unfair Employment Practices (OSC) issued a carefully worded technical assistance letter addressing the complex interplay between U.S. immigration and export control laws in the context of hiring and applicant screening. Although it provides limited new guidance, OSC’s letter is a… Continue Reading

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