Insight
FinCEN’s Beneficial Ownership Reporting Rule Suspended Again
On February 27, 2025, FinCEN announced that it will not issue any fines or penalties or take any other enforcement action against companies for failing to comply with the beneficial ownership information (“BOI”) reporting requirements under the Corporate Transparency Act. As such, reporting companies are no longer required to file BOI reports by the March 21, 2025 or other applicable deadline. However, FinCEN has indicated that it intends to issue an interim final rule no later than March 21, 2025, which will set new reporting deadlines and provide new guidance on the reporting requirements.
04 March 2025
Insight
SEC's New Short Sale Reporting Rule and Temporary Exemption
In an order issued on February 7, 2024, the U.S. Securities and Exchange Commission (the “SEC”) granted a temporary exemption to institutional investment managers required to report certain information with regard to certain equity securities on Form SHO pursuant to Rule 13f-2, delaying the initial filing deadline to February 14, 2026 for the January 2026 reporting period, giving the industry more time for compliance. In a final rule-making issued on October 13, 2023, the SEC adopted a new Rule 13f-2 and the related Form SHO , imposing new short sale reporting obligations on institutional investment managers. The new rule is designed to enhance market transparency and regulatory oversight of short-selling activities, in response to concerns about manipulative or abusive short selling and the lack of transparency of short positions to both market participants and regulators. The new Rule 13f-2 came into effect on January 2, 2024, and the original compliance date was January 2, 2025. In this client alert, we will provide a brief overview of the reporting requirements under the new Rule 13f-2 and discuss the new rule’s implications for institutional investment managers, including non-U.S. fund and asset managers, and our recommended next steps.
26 February 2025
Insight
TMT: China’s Pilot Scheme for Value-Added Telecom Services
The Ministry of Industry and Information Technology (MIIT) of China has recently introduced the Pilot Scheme for the Further Opening of Value-Added Telecom Services to Foreign Investment (Pilot Scheme). This initiative represents a significant evolution in the regulatory framework governing foreign investment within China’s TMT sector, lifting ownership restrictions for Foreign-Invested Enterprises (FIEs) within designated zones with respect to certain value-added telecom services. As the Pilot Scheme unfolds, stakeholders should stay attuned to evolving regulations and navigate the complexities of telecommunications business classifications. Now, let’s explore the key provisions of this significant legislation.
09 May 2024
