Earlier this year, the Michigan House of Representatives introduced several new bills aimed at fostering blockchain innovation and addressing certain open issues regarding the treatment of digital assets. As discussed herein, one of these bills, HB 4511 of 2025, provides digital asset users and associated service providers helpful guidance on the state’s current approach to this technology while reflecting broader policy trends at the state and federal levels.

The Department of Justice’s (DOJ) new Bulk Transfer Rule is intended to protect against countries of concern from receiving personal information on U.S. citizens due to national security concerns, placing precise geolocation data at the center of scrutiny. Companies will struggle to understand whether the rule's requirements apply to the vast amounts of location-enabled data they are collecting and processing.

On August 4, 2025, the USPTO issued critical guidance that could significantly reduce § 101 rejections for AI and software patents. This memorandum reinforces existing law but provides examiners with clearer boundaries and a higher standard for making eligibility rejections. For companies developing AI, machine learning, and software technologies, this guidance represents a more favorable examination environment and opportunities to overcome previously problematic rejections.

On August 15th, Treasury and the IRS released Notice 2025-42, which sets out the controlling standards for when construction is treated as having begun, narrows reliance on prior safe harbors, and details continuity, contracting, transferring, and low-output solar rules.

Now more than ever, employers must ensure that they are complying with federal immigration law, which requires verification of the identity and work authorization of employees and prohibits employers from hiring unauthorized workers in light of three significant shifts in federal policy.

On July 29, 2025, the DOJ released new guidance clarifying the legal boundaries of Diversity, Equity, and Inclusion (DEI) initiatives for recipients of federal funds. Employers that receive federal funding should take note of these developments to ensure compliance and minimize exposure to legal and financial risk.

In today’s digital landscape, cybersecurity and data privacy must be part of the core strategy—not an afterthought. These are not just “big company” concerns. Cybersecurity threats and compliance requirements impact every player in the renewable space, regardless of size or budget.

On July 4, 2025, President Trump signed into law the tax and spending bill colloquially known as the “One Big Beautiful Bill” (OBBB). The OBBB, which represents the most significant overhaul of federal tax law since passage of the 2017 Tax Cuts and Jobs Act (TCJA) during President Trump’s first administration, makes permanent and enhances many of the tax-reduction provisions contained in the TCJA that were scheduled to sunset at the end of 2025. This alert is a high-level summary of certain key provisions of the OBBB affecting individuals, businesses, employers, international taxpayers and the energy sector.

Recent developments in U.S. policy giving rise to enforcement action by the U.S. Department of Treasury’s Financial Enforcement Network (FinCEN) sound a cautionary note for U.S. financial institutions. An article we recently posted regarding the U.S. Department of Justice’s updated guidelines regarding the Foreign Corrupt Practices Act, called attention to the Trump administration’s focus to “pursue the total elimination of Cartels and transnational criminal organizations”. This latest FinCEN enforcement action further defines this focus.

On June 9, 2025, the U.S. Department of Justice (“DOJ”) issued updated Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act. The Guidelines comply with President Trump’s February 10, 2025 Executive Order 14209 and follow Attorney General Pam Bondi’s February 5, 2025 Memorandum, both of which focus on prioritizing “American interests, American economic competitiveness with respect to other nations, and the efficient use of Federal law enforcement resources.”

The U.S. Court of International Trade (USCIT or the Court) has ruled most of President Trump’s tariffs illegal, finding he exceeded his authority in imposing sweeping tariffs on China and global trading partners based on the International Emergency Economic Powers Act (IEEPA). The Court vacated most of the Trump tariffs, and gave up to ten days for the President to terminate the tariff collections process.

On May 22, 2025, the U.S. House of Representatives passed H.R. 1, titled the “One Big Beautiful Bill Act” (“House Bill”), a budget reconciliation bill that introduces sweeping changes to the Inflation Reduction Act (“IRA”) clean energy tax credits. This legislation, which passed by a narrow, party-line vote, could profoundly impact the renewable energy sector by accelerating the phaseout of key incentives and imposing stringent timelines for project eligibility.

On May 15, 2025, the U.S. Securities and Exchange Commission (“SEC”) took significant actions towards facilitating the ability of broker-dealers to custody and transfer agents to record ownership of digital assets.

In an era of rising political scrutiny and shifting legal interpretations, many employers are asking the same question: Can we still do DEI? The short answer, according to former EEOC Commissioner Chai Feldblum, is a resounding yes—as long as it’s done lawfully, thoughtfully, and inclusively. Given the current political and legal climate, it’s crucial for employers to understand how to navigate these complexities while maintaining their commitment to diversity, equity, and inclusion.

A recent appellate court decision in Florida highlighted the imperative for behavioral health treatment facilities to implement effective discharge planning, particularly in the case of Anthony Burley, who overdosed 48 days after being discharged with minimal support. The Court's ruling reaffirmed that facilities have a continuing duty of care that includes ensuring appropriate post-discharge referrals and services to prevent tragic outcomes.

On March 12, 2025, the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission issued a no-action letter to Latham & Watkins LLP, providing interpretive guidance on verifying accredited investor status under Rule 506(c) of Regulation D. The no-action letter clarifies that issuers can rely on minimum investment amounts, coupled with certain written representations and conditions, as a factor in taking reasonable steps to verify that purchasers in a Rule 506(c) offering are accredited investors.

(In Japanese) On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued a public notice announcing that “it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership information (BOI) reports pursuant to the Corporate Transparency Act by the current deadlines.” The announcement effectively suspended enforcement of FinCEN’s own March 21, 2025 reporting deadline, which it issued on February 18, 2025. FinCEN also announced that it intends to issue an interim final rule by March 21, 2025 that will extend reporting deadlines and will also solicit public comment on potential revisions to CTA reporting.

On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued a public notice announcing that “it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership information (BOI) reports pursuant to the Corporate Transparency Act by the current deadlines.” The announcement effectively suspended enforcement of FinCEN’s own March 21, 2025 reporting deadline, which it issued on February 18, 2025. FinCEN also announced that it intends to issue an interim final rule by March 21, 2025 that will extend reporting deadlines and will also solicit public comment on potential revisions to CTA reporting.

(In Japanese) The stays of the two nationwide injunctions pending appeals mean that beneficial ownership information (“BOI”) reporting under the CTA is once again in effect. The Financial Crimes Enforcement Network (“FinCEN”) issued a public notice yesterday confirming that the CTA is back in effect and extending the deadline for BOI reporting to March 21, 2025.

The stays of the two nationwide injunctions pending appeals mean that beneficial ownership information (“BOI”) reporting under the CTA is once again in effect. The Financial Crimes Enforcement Network (“FinCEN”) issued a public notice yesterday confirming that the CTA is back in effect and extending the deadline for BOI reporting to March 21, 2025. Separately from the CTA, the New York LLC Transparency Act became effective on January 1, 2025.