Subject to Inquiry

On April 17, 2024, the Consumer Financial Protection Bureau entered an order against a for-profit vocational school and its CEO for mischaracterizing the school’s income-share agreements (ISAs)...

https://www.subjecttoinquiry.com/2024/04/cfpb-for-profit-school-misrepresented-isas-made-false-claims-about-grads-employment-rates/

On April 2 and 3, 2024, U.S. Securities and Exchange Commission Chair Gary Gensler, Division of Enforcement Director Gurbir Grewal and other senior SEC officials convened at the SEC Speaks confer...

https://www.subjecttoinquiry.com/2024/04/sec-speaks-2024-in-defense-of-the-enforcement-divisions-agenda/

On March 6, the SEC released its long-anticipated adopting release amending Rule 605.  Separately, in late February, FINRA issued Regulatory Notice 24-05 discussing new FINRA Rule 6151, which re...

https://www.subjecttoinquiry.com/2024/04/spring-has-sprung-for-recent-reg-nms-reporting-changes/

On March 7, 2024, U.S. Deputy Attorney General Lisa Monaco gave remarks at the American Bar Association’s 39th National Institute on White Collar Crime in San Francisco, California. Monaco prov...

https://www.subjecttoinquiry.com/2024/03/deputy-attorney-general-monaco-announces-new-doj-whistleblower-program/

On March 1, 2024, the United States District Court for the Northern District of Alabama declared the Corporate Transparency Act (“CTA”) unconstitutional.  Enacted as part of the Anti-Money L...

https://www.subjecttoinquiry.com/2024/03/federal-district-court-declares-corporate-transparency-act-cta-unconstitutional/

On February 1, 2024, the G7+ Coalition (consisting of the G7, the European Union, and Australia) published an Oil Price Cap (OPC) Compliance and Enforcement Alert (the “Alert”), identifying n...

https://www.subjecttoinquiry.com/2024/02/g7-coalition-issues-alert-on-russian-oil-price-cap-evasion-methods-and-how-to-report-violations/

Rule Regarding Access to Beneficial Ownership Information Takes Effect On February 21, 2024, FinCEN published a Small Entity Compliance Guide to aid in compliance with the Corporate Transparency ...

https://www.subjecttoinquiry.com/2024/02/fincen-issues-access-rule-compliance-guide/

The Bank Secrecy Act (“BSA”) establishes program, recordkeeping, and reporting requirements for certain financial institutions to combat and detect money laundering, terrorist financing, and ...

https://www.subjecttoinquiry.com/2024/02/bank-secrecy-acts-anti-money-laundering-counter-terrorism-financing-requirements-apply-investment-advisers/

During a summit celebrating its one-year anniversary, the Disruptive Technology Strike Force provided updates on its efforts to prevent authoritarian regimes and hostile nation-states from acquir...

https://www.subjecttoinquiry.com/2024/02/disruptive-technology-strike-force-continues-focus-on-trade-secret-theft-export-control-enforcement/

On January 16, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance to incentivize voluntary self-disclosure (“VSD”) of possible violatio...

https://www.subjecttoinquiry.com/2024/02/bis-continues-enforcement-policy-ramp-up/