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Amy Gordon

Amy Gordon is an associate in the Litigation Department and a member of the Mass Torts & Product Liability, Privacy & Cybersecurity and White Collar Defense & Investigations groups. Her practice encompasses a range of complex civil and commercial litigation matters across a range of industries, including financial services, consumer products and telecommunications. Amy has also advised clients across industries on economic sanctions and asset forfeiture related issues.

Amy has experience with various stages of litigation, including taking and defending depositions, briefing dispositive and discovery motions, coordinating discovery and preparing witnesses for depositions and trial.

Amy maintains an active pro bono practice, including representing clients in litigation to improve housing conditions. In addition, she undertook a five-month secondment while at the Firm, where she worked for the City of New York in the General Litigation Unit.

Amy earned her J.D. from the University of Texas School of Law, where she was a Cybersecurity Graduate Fellow and served as Chief Notes Editor for The Review of Litigation. During law school, Amy interned for the Honorable Nicholas G. Garaufis in the United States District Court for the Eastern District of New York.

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Today, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule aimed to ease compliance with certain aspects of the regulations promulgated under the Corporate Transparency Act.  The final rule extends the deadline from 30 days to 90 days for entities created or registered during 2024 that do not qualify for an…

As the effective date of the US federal Corporate Transparency Act approaches, FinCEN continues to develop its rules almost on a daily basis. Within the past few days, the Financial Crimes Enforcement Network (“FinCEN”) published notice of proposals aimed to clarify and ease compliance with certain aspects of the regulations promulgated under the Corporate Transparency Act. The Corporate Transparency Act requires certain entities (“reporting companies”) to report to FinCEN information about their beneficial owners and company applicants, and is intended to help prevent and combat money laundering, terrorist financing, tax fraud and other illicit activity.[1] The Beneficial Ownership Reporting Rule (the “BOI Rule”), promulgated by FinCEN in September of 2022, establishes who are reporting companies and their beneficial owners and company applicants, as well as what information is required to be reported about these entities and individuals.

In 2021, the U.S. enacted the Corporate Transparency Act (the “CTA”) as part of a multi‑national effort to rein in the use of entities to mask illegal activity.  The CTA directs the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) to propose rules requiring certain types of entities to file a report identifying the entities’ beneficial owners and the persons who formed the entity.  FinCEN issued the final rule on Beneficial Ownership Information Reporting Requirements (the “Reporting Rule”) on September 29, 2022. FinCEN recently published a Small Entity Compliance Guide intended to assist entities in determining whether they are required to file a report and what information will need to be reported.  The Reporting Rule will become effective on January 1, 2024.

On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering Act of 2020 in the National Defense Authorization Act for Fiscal Year 2021.  Congress passed the CTA to “better enable critical national security, intelligence, and law enforcement efforts to counter money laundering, the financing of terrorism, and other illicit activity.” The CTA requires a range of entities, primarily smaller, otherwise unregulated companies, to file a report with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) identifying the entities’ beneficial owners—the persons who ultimately own or control the company—and provide similar identifying information about the persons who formed the entity. The CTA also authorizes FinCEN to disclose this information to authorized government authorities and to financial institutions in certain circumstances.

Antitrust and tech is in the legal news almost daily, and often multiple times a day.  Here are a few recent developments with notable implications that may have flown under the radar: 1) renewed focus on gig economy issues; 2) potential enforcement efforts regarding director overlaps; and 3) challenges to MFN pricing.