Journal

Notes.

Brief, time-sensitive commentary on the developments that warrant a short, well-sourced note.

Note · May 22, 2026

FinCEN’s Refreshed Screening Guidance: An Operator’s Reading

FinCEN’s recent screening guidance reaches further than the public statement might suggest. Reporting institutions should reassess transaction-monitoring scope, ownership analysis, and the evidentiary trail supporting every risk-based decision.

7 minRead →
Note · April 30, 2026

EU Indirect-Tax Reform 2026: Cross-Border Structures

The European Commission’s 2026 indirect-tax reform package introduces significant changes to VAT treatment of cross-border digital services and certain B2B transactions.

6 minRead →
Note · April 22, 2026

Corporate Transparency Act: Refined Guidance Tightens the Reporting Picture

FinCEN’s refined CTA guidance clarifies reporting expectations and introduces meaningful enforcement risk for incomplete or stale filings.

5 minRead →
Note · February 17, 2026

Non-Compete Doctrine After the Circuit Decisions

Recent appellate decisions have clarified the legal status of the FTC non-compete rule. Employers should review existing agreements.

5 minRead →
Note · February 11, 2026

U.K. AML Enforcement: What the FCA’s Findings Signal for Cross-Atlantic Banks

A high-profile FCA enforcement action against a major U.K. financial institution clarifies the standards expected of AML monitoring, escalation, and remediation.

5 minRead →
Note · February 6, 2026

EB-5 Investor Immigration: 2026 Reauthorisation

Recent EB-5 reauthorisation legislation, combined with USCIS visa-bulletin movements, creates new strategic windows for candidates and Regional Centers.

5 minRead →
Note · January 30, 2026

Supreme Court Reshapes Arbitration

A recent Supreme Court decision clarifying the boundaries between arbitral and judicial authority will reshape commercial-arbitration practice.

6 minRead →
Note · January 24, 2026

OFAC Secondary Sanctions: Calibrating Defensive Posture

OFAC’s expanded use of secondary sanctions creates new operational risk for non-U.S. financial institutions and corporates.

5 minRead →