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On April 2, 2025, President Donald Trump announced a new tariff regime under the International Emergency Economic Powers Act of 1977 (“IEEPA”), citing national security concerns. This regime includes a 10 percent baseline tariff for all countries and higher “reciprocal tariffs” for approximately 90 countries, effective April 5, and April 9, 2025, with additional potential tariffs threatened in the future. The new tariffs would significantly impact corporations, particularly those with supply-chain exposure in China and other Southeastern Asian countries.
On April 28, 2025, the U.S. Attorney’s Office for the Eastern District of Virginia (“EDVA”) and the U.S. Department of Justice’s (“DOJ”) Civil Rights Division (“CRT”) announced the formation of the Eastern District of Virginia Equal Access to Banking Task Force.
V&E White Collar Update
On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced a suspension of enforcement actions related to the Corporate Transparency Act (“CTA”).
V&E CTA Update
As we previously discussed, on January 7, 2025, the U.S. District Court for the Eastern District of Texas issued a nationwide injunction delaying the implementation of the Corporate Transparency Act’s (“CTA”) reporting requirements (Smith, et al. v. U.S. Department of the Treasury).
V&E CTA Update
Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt Practices Act of 1977, as amended (the “FCPA”), and signaled a coming shift in how the statute will be enforced in the future.
V&E Foreign Corrupt Practices Act Update
On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction that was issued by a Texas federal judge in the case Texas Top Cop Shop, Inc. v. McHenry.
V&E CTA Update
As Donald J. Trump prepares to begin his second presidential administration on January 20, 2025, many Department of Justice (“DOJ”) priorities and policies are likely to change.
V&E Government Investigations & White Collar Update
As we previously discussed, on December 5, 2024, the Department of Justice (“DOJ”), representing the Department of the Treasury, submitted a notice of appeal to the U.S. Court of Appeals for the Fifth Circuit, challenging a memorandum opinion and order issued by Judge Mazzant of the U.S. District Court for the Eastern District of Texas.
V&E CTA Update
As we approach Inauguration Day on January 20, 2025, one question among anti-corruption practitioners is how the Trump administration will handle enforcement of the Foreign Corrupt Practices Act (“FCPA”).
V&E Foreign Corrupt Practices Act Update