In response to the COVID-19 pandemic, the staffs at the Federal Trade Commission (FTC) and Department of Justice (DOJ) responsible for Hart-Scott-Rodino (HSR) merger reviews are working remotely. Accordingly, HSR filings cannot be made in hard copy — which is the only way those filings have been made in the past. In order address this situation, the FTC Premerger Notification Office has set up a temporary electronic platform to enable parties to make their HSR filings electronically. The new platform went live on Tuesday, March 17. Given the dislocations caused by these changes, the FTC has advised that it will not be granting Early Termination of the HSR Waiting Period on electronic filings at this time. Accordingly, parties who need HSR clearance on their transactions should factor in a full 30 days for HSR clearance in setting their timetables for closing.
Continue Reading COVID-19 Update – Hart-Scott-Rodino Filings

The US Attorney’s Office in the Northern District of California recently settled an enforcement action against Ripple Labs Inc., a Delaware corporation providing virtual currency exchange services. According to the settlement agreement, Ripple Labs was not registered with the Financial Crimes Enforcement Network (FinCEN) as a money services business (MSB) pursuant to the Bank Secrecy Act of 1970 while engaged in currency trading, and lacked required anti-money laundering controls.
Continue Reading Department of Justice Settles Virtual Currency Enforcement Action