FinCEN Releases Final Rule Clarifying Money Services Businesses Definitions, Includes Foreign-located MSBs Doing Business in U.S.

On July 18, 2011, the Financial Crimes Enforcement Network of the United States Department of the Treasury (“FinCEN”) issued a final rule amending the Bank Secrecy Act (BSA) implementing regulations regarding Money Services Businesses (“MSBs”). The rule clarifies which businesses qualify as MSBs and are thus subject to the anti-money laundering regulations of the BSA. A copy of FinCENs press release can be read here.

Under current BSA regulations, businesses that meet one or more of the definitions of a MSB must comply with applicable BSA requirements. Businesses which qualify as MSBs under BSA regulations include: currency dealers, currency exchangers, check cashers, money transmitters as well as sellers issuers and redeemers of travelers checks, money orders, or stored value.

The rule makes several changes to MSB regulations starting with the definition of an MSB itself. The definition of MSB has been rephrased to state: “[a] person wherever located doing business, whether or not on a regular basis or as an organized or licensed business concern, wholly or in substantial part within the United States” in one or more of the capacities listed above. The new rule clarifies that it is the activities performed by a business within the US which will cause it to be classified as an MSB regardless of that businesses location.

Additionally, the new rule makes foreign-located businesses engaging in MSB activities within the US subject to BSA regulation. As a result, even foreign based MSBs with no physical presence in the US can be classified as an MSB and thus subject to the rigorous requirements of the BSA. However, foreign banks as well as foreign financial agencies that engage in activities that if conducted in the US would require them to be registered with the SEC or CFTC are excluded from the definition of an MSB. As noted in the rule, “To permit foreign-located persons to engage in MSB activities within the United States and not subject such persons to the BSA would be unfair to MSBs physically located in the United States and would also undermine FinCENËœs efforts to protect the U.S. financial system from abuse.”

The rule also replaces the terms “currency dealer or exchanger” with “dealer in foreign exchange” and clarifies what services will qualify for this MSB category. Although the BSA uses the term “currency exchange,” FinCEN has interpreted the Act as intending to cover the underlying activities involved in foreign exchange services, including the exchange of instruments other than currency. As a result, “dealer in foreign exchange” will be defined as: “A person that accepts the currency, or other monetary instruments, funds, or other instruments denominated in the currency, of one or more countries in exchange for the currency, or other monetary instruments, funds, or other instruments denominated in the currency, of one or more other countries in an amount greater than $ 1,000 for any other person on any day in one or more transactions, whether or not for same-day delivery.” This new term and definition makes clear that exchanges within the US of currency, funds, or monetary instruments wholly between foreign currencies still classify a business as an MSB and subject to BSA regulation.

FinCENs new rule also provides for several changes to the definition of “check casher” in an effort to more accurately describe which activities are covered. First, the rule splits the definition of “check casher” into two paragraphs, the first defining what activity is considered “check cashing” and the second listing exclusions from the definition. Second, FinCEN has now incorporated the redeeming of monetary instruments into its definition of “check cashing.” As a result businesses engaged in redeeming monetary instruments, including money orders and travelers checks, will be considered a check casher if it also redeems checks for currency or a combination of currency and monetary or other instruments. “Check cashing” is now defined as: “A person that accepts checks (as defined in the [UCC]), or monetary instruments in return for currency or a combination of currency and other monetary instruments in an amount greater than $1,000 for any person on any day in one or more transactions.”

The new rule amends existing MSB regulations by separating the provisions concerning stored value from those concerning issuers, sellers, and redeemers of travelers checks and money orders. FinCEN separated out the stored value provisions in anticipation of additional changes to be made regarding stored value in FinCENs Prepaid Access Rulemaking. See our previous report for more information regarding FinCENs Prepaid Access Rulemaking. The rule also combines the previously separate categories of issuer of travelers checks and money orders and seller of travelers checks and money orders into one category.

The rule also provides for several changes to the definition of “money transmitter” and exclusions from its coverage. While substantive, these changes incorporate years of FinCEN issued guidance and administrative rulings regarding examples of activities which would not classify a business as a money transmitter, even though the business engaging in such activities may be involved in accepting and transmitting funds. A complete copy of the new rule can be read here.

If you have questions pertaining to the BSA, anti-money laundering compliance or how to ensure that your business maintains regulatory compliance at both the state and federal levels, contact Fuerst Ittleman PL at contact@fidjlaw.com.

Democratic Senator Challenges Tax Shelters and Offshore Havens

Senator Carl Levin (D-Mich) unveiled legislation last week that seeks to limit offshore tax loopholes and strengthen American enforcement capabilities. The senator has introduced similar measures in the past, but is hopeful that Washingtons current focus on the deficit will carry his latest proposal “over the goal line.”

Amid concerns about $100 billion in lost annual tax revenues and the resulting burden on middle America, the bill aims to give the Treasury department new tools to collect its share. One section would authorize the Treasury Secretary to take special enforcement measures against uncooperative offshore institutions. Another section would create rebuttable presumptions to give the IRS more power over offshore entities. Other provisions seek to define foreign companies with most of their management or operations in the U.S. as domestic companies for tax purposes. Additionally, the bill would require multinationals to provide the Securities and Exchange Commission with basic information about its operations in other countries, for example, its number of employees and tax obligations.

The bill would also make all credit default swaps (“CDS”) that originate in the U.S. subject to U.S. taxation. Currently, CDS payments are taxed according to where the money is sent, meaning not all swaps sourced in the U.S. are taxed here. The bill would deem CDS funds deposited into U.S. accounts as taxable distributions by the foreign subsidiaries to their U.S. parents.

One particular feature of the bill would toughen penalties on tax shelter promoters and aider and abettors of tax evasion by increasing the maximum fine to 150% of any illegal gains.

The bill, entitled the Stop Tax Haven Abuse Act, is supported by a wide array of small business, labor, and public interest groups, including the Financial Accountability and Corporate Transparency (FACT) Coalition, American Sustainable Business Council, Business for Shared Prosperity, and others.

Read about other features of the Stop Haven Abuse Act on Sen. Levins website.

Although Sen. Levin was unable to estimate how much tax revenue his bill would recover, he wants any new revenues to be used for paying down the deficit. “Offshore tax abuses are not only undermining public confidence in our tax system, but increasing the tax burden on middle America,” stated Levin. “People are sick and tired of tax dodgers using offshore trickery and abusive tax shelters to avoid paying their fair share.”

The attorneys at Fuerst Ittleman are current and knowledgeable on todays pressing tax issues. If you have any domestic or offshore tax concerns, email an attorney at contact@fidjlaw.com.

FDA Issues Draft Guidance for New In Vitro and Radiology 510(k) Exemptions

On July 12, 2011, the FDA issued a draft guidance which outlines FDAs enforcement policy regarding certain Class II medical devices and 510(k) premarket notification requirements. The draft guidance was issued in anticipation of a rule reclassifying certain in vitro and radiology Class II devices as Class I. A complete list of the devices can be found in the draft guidance. The reclassification of devices is one component of the agencys plan to overhaul the system for reviewing and clearing medical devices. Please see our previous report on the FDAs plan here and the FDAs draft guidance on in vitro companion diagnostic devices here.

The FDA classifies medical devices based on perceived risk using a 3-tier system. Class I medical devices have the lowest perceived risk, and do not require a formal FDA review before marketing. Class II medical devices have a higher perceived risk than Class I, and require the submission of a 510(k) premarket notification or premarket notification application (PMA). Class III medical devices have the highest perceived risk, and require the submission of a PMA. The draft guidance states that the enforcement of 510(k) requirements is to evaluate the safety and effectiveness of a device. According to the draft guidance, the FDA believes that the in vitro and radiology Class II devices now receiving a 510(k) exemption are sufficiently well-established and have sufficiently controlled the risks that are necessary to assure the safety and effectiveness; thus, those devices can now be reclassified as Class I.

The FDA is currently seeking public comment on the draft guidance; the deadline for submission is August 16, 2011.

The FDAs review of medical devices through the 510(k) process is complex. Fuerst Ittleman has extensive experience successfully navigating medical devices through FDA review. For more information on FDAs review of medical devices, please contact us at contact@fidjlaw.com.

FSMA Checklist: Dietary Supplement Guidance and Anti-Smuggling Strategy

Pursuant to the Food Safety and Modernization Act (FSMA), the U.S. Food and Drug Administration (FDA) is required to meet various deadlines for the implementation of new food safety systems. July 3, 2011 marked 180 days since President Obama signed the FSMA into law as well as the deadline for completing the new dietary supplement ingredient guidance and an anti-smuggling strategy. On July 5th the FDA announced it had completed two tasks required by the FSMA.

New Dietary Supplement Ingredient Guidance

The first task completed by the FDA was issuing the draft guidance intended to assist industry in deciding when a premarket safety notification for a dietary supplement containing a new dietary ingredient (NDI) is necessary. Manufacturers of dietary supplements are required to notify the FDA in advance, through a premarket safety notification, when adding a new ingredient with an unknown safety profile to their products. Manufacturers must also provide evidence that the ingredient is safe for consumers.

It appears that the agencys regulatory interpretation of NDIs is more restrictive than the statutory language, thus creating substantial hurdles for manufacturers. The draft guidance provides what specifications should be included in an NDI, such as the type and amount of evidence, in order to establish that a dietary supplement is “reasonably expected to be safe.” 21 USC §350b(a)(2). The draft guidance consists of more than 120 Q&As regarding the determination of, whether a dietary ingredient is an NDI, whether a notification is required, and what information should be included in the notification.

The draft guidance also states that the FDA will alert the Drug Enforcement Administration (DEA) if a notice is deemed inadequate because the ingredient is an anabolic steroid or a material with the same chemical qualities.

The FDA is currently seeking public comment on the draft guidance; the deadline for submission is October 3, 2011.

Anti-Smuggling Strategy

The second task was the development of an anti-smuggling strategy. The Department of Health and Human Services (HHS) and the Department of Homeland Security (DHS) developed the new anti-smuggling strategy in order to identify and prevent the entry of smuggled food into the U.S. that could be dangerous to national security and consumer safety. HHS and DHS are working closely with Customs and Border Protection (CBP) and Immigration and Customs Enforcement (ICE) to identify import shipments that could conceal undeclared foods.

Food may be smuggled for many reasons including economic gain, to evade import taxes, evade routine inspection that could raise safety concerns, or for more dangerous reasons, including plots to intentionally harm the American public. The strategy will focus on imported foods that pose a significant public health threat.

Fuerst Ittleman will continue to monitor the implementation FSMA food safety goals. For more information on the FSMA, regulation of dietary supplements, or the anti-smuggling strategy, please contact us at contact@fidjlaw.com.

Patient Receives First Fully Synthetic Organ Transplant

Last month, a 36 year-old cancer patient received the worlds first trachea implant made of his own stem cells grown on a man-made plastic matrix. Researchers from Sweden, England and the U.S. collaborated in Stockholm to create the trachea from scratch in 48 hours.

The procedure began by removing the patients bone marrow and filtering out certain cells, called mononucleocytes. Those cells were then treated with growth factors in order to morph into the cells that form the rings of the trachea. The cells and the plastic matrix were then placed in a bioreactor which rotates the matrix once per minute dipping the matrix into the cells. Within 48 hours, the cells grew around the matrix and the trachea was ready for implant.

Although a similar procedure was completed in 2008, this procedure is the first to transplant a wholly synthetic trachea without relying on human donation. In 2008, a patient in Barcelona received a trachea that had been removed from an organ donor and, over a period of weeks, cleared of all of its original cells, leaving just a matrix that could be coated with the patient’s own stem cells.

The synthetic organ transplant was deemed a success when the patients body accepted the new trachea. Researchers say the application of growth of synthetic organs from stem cells may help children, who lack as many donated organs as adults. The next patient who will receive a similar procedure is a 9-month-old girl who was born without a trachea.

Fuerst Ittleman recognizes the promise that stem cells hold for regenerative medicine. We will continue to monitor future stem cell procedures and other stem cell studies. For more information the regulatory oversight of stem cells, contact us at contact@fidjlaw.com.

FDA Proposes Guidance Document for In Vitro Companion Diagnostic Devices

Last week, the U.S. Food and Drug Administration (FDA) announced the release of a guidance document for in vitro companion diagnostic devices. According to the FDA, companion diagnostics are “tests used to help health care professionals determine whether a patient with a particular disease or condition should receive a particular drug therapy or how much of the drug to give.” These diagnostic tests enhance the effectiveness of targeted treatments because they help to determine whether a patient is a genetic fit for a particular therapy. The guidance document clarifies the definition of a companion diagnostic and also provides guidance on the agency’s proposed policy for reviewing in vitro diagnostics and corresponding targeted therapies. The FDA is seeking public input on the draft guidance for 60 days.

The release of this new guidance document marks a significant change in the way the FDA has regulated these types of technologies. In particular, the guidance document signals a shift in the FDA’s regulation of companion diagnostic devices from enforcement discretion to risk-based oversight. The FDA intends to use the same risk-based process it uses to regulate all other medical devices, where the device’s regulatory pathway is determined by the level of risk to patients based on the device’s intended use and any concerns pertaining to its safety and effectiveness. Diagnostic devices will require submission of a premarket approval (PMA) or 510(k) premarket notification.

The FDA suggests that manufacturers should engage the FDA in the early stages of developing their products. The Agency also recommends that manufacturers develop therapeutic products and companion devices contemporaneously to facilitate the acquisition and review of clinical performance and clinical significance data. The guidance document suggests that the FDA will only approve targeted treatments after the corresponding companion device has gained FDA approval or clearance. The FDA outlined two exceptions where it may approve a targeted therapy before a companion diagnostic is approved: 1) when the therapy is intended to treat a serious or life-threatening disease or 2) where a condition has no available or satisfactory treatment and the potential benefits outweigh the risk of not having a cleared or approved companion device. In those cases, the FDA may approve a targeted therapy and clear or approve the device at a later time.

The FDA’s proposed guidance document for in vitro companion diagnostic devices raises interesting questions about how the FDA will continue to regulate similar types of industries, such as laboratory-developed tests (LDTs), where the FDA currently exercises enforcement discretion. While it is unclear whether the FDA will make changes to other industries that utilize similar technologies, the proposed guidance for FDA regulation of a companion diagnostic may be an indication that the FDA is moving away from enforcement discretion and is shifting toward a preference for a risk-based regulatory scheme.

Fuerst Ittleman will continue to monitor the progress of the FDA’s regulation of therapeutic and diagnostic devices. For more information, please contact us at contact@fidjlaw.com.

Organic Labeling of Cosmetics under Scrutiny in California

The Center for Environmental Health (CEH), a public advocacy group in California, filed suit in the Superior Court of the State of California on June 16, 2011, against 26 cosmetic companies alleging companies sold their products with the aid of misleading organic product labels. CEH, seeking injunctive relief, wants to encourage cosmetic companies to use organic ingredients and ensure that consumers can trust organic labels.

Cosmetics labeled and advertised as organic are subject to several different regulations. The U.S. Food and Drug Administration (FDA) regulates cosmetics under the Federal Food, Drug, and Cosmetic Act and the Fair Packaging and Labeling Act. However, neither of these laws gives the FDA authority to enforce organic claims. The U.S. Department of Agriculture (USDA) regulates the term “organic” as it applies to agricultural products through the National Organic Program (NOP). If a cosmetic is manufactured from agricultural ingredients and is labeled as “organic,” it must meet the NOP standards for certified organic labeling. The Federal Trade Commission (FTC), pursuant to section 5 of the FTC Act, prohibits unfair or deceptive advertisement claims for cosmetics, including deceptive organic claims. Cosmetics sold in California are subject to additional requirements set forth under the California Organic Products Act of 2003 (COPA).  

According to the Complaint, CEH claims it found dozens of products made by the 26 defendant companies that are labeled organic, yet contain few or, in some cases, no organic ingredients. Pursuant to COPA, cosmetic products labeled with the term “organic” on the front of the package must contain at least 70 percent organic ingredients. Those products with less than 70 percent may only use the term "organic" on the ingredient list. COPA gives any person standing to file an action to enjoin a party from violating COPA. Additionally, a plaintiff is not required to show injury or damages under COPA in an action for injunctive relief.

Advocates are concerned with the lack of federal cosmetic regulation. Currently, the FDA has a Voluntary Cosmetic Registration Program which allows firms to voluntarily register their facilities and list their products and ingredients. There is no regulation requiring that a cosmetic label be approved prior to use. Advocates were hopeful for the passage of the Safe Cosmetics Act of 2010, which would have increased the FDA’s regulation of cosmetics. However, they were disappointed when the act never made it past the House committee for vote. See our previous report here for more information on the 2010 Safe Cosmetics Act. See our report here on the 2011 Safe Cosmetics Act, which currently in the House committee. With the FDA’s resources focused on food safety and medical device reform, state legislation and lawsuits like that filed by CEH in California state court may be the most immediate and effective means of regulating the manufacture and sale of “organic” cosmetics.

For more information on regulation of the cosmetic industry, please contact us at contact@fidjlaw.com.

Labeling Guidance Of Genetically Modified Food Gains Approval

On July 5, 2011, regulators from the worlds food safety regulatory agencies gathered at the Codex Summit in Geneva, Switzerland to vote on food labeling guidance for genetically modified foods. Genetically modified foods (“GM foods”), food products derived from organisms whose genetic makeup have been altered through genetic engineering, have been on the international market since the early 1990s. This annual summit was organized by the Codex Alimentarius Commission, a body created in 1963 by the Food Agriculture Organization and World Health Organization to develop international food standards, guidelines, and related texts. Representatives from over 100 countries attended the Summit and approved GM food labeling guidance, which allows countries to label genetically modified foods without risking violation of international free trade laws.

After a 20-year struggle among international food safety bodies, the United States surprised attendees of the Codex Summit by ending their opposition to the proposed GM food labeling guidance. The United States has traditionally opposed GM food labeling because it believes GM food products on the market have been sufficiently tested and deemed safe for human consumption. Nevertheless, the United States changed its position because “this adopted text clarifies that foods derived from modern biotechnology are not necessarily different from other foods simply due to their method of production.” The United States, however, remains opposed to proposals that make GM food labeling mandatory.

As a result of the affirmative vote at the Codex Summit last week, the GM food labeling guidance document will become an official Codex text. Because national measures based on Codex guidance or standards cannot be challenged as a barrier to trade, the passage of this new guidance provides any country the freedom to adopt the new labeling system without the threat of legal sanctions from the World Health Organization.

By passing these new labeling guidelines, countries will now have the opportunity to conduct post-market monitoring of the effects of GM food products on the publics health. Countries that adopt the labeling guidance can better track information about GM foods because consumers can report any allergies or adverse reactions from exposure to foods containing GM products or foods derived from modern biotechnology. The Food and Drug Administration (FDA) is responsible for regulating food products that are sold on the market in the United States, whether produced domestically or imported from foreign nations. Even though the new labeling guidance requires new national legislation to refer to the “scientific uncertainty of risks” and the need for post-market surveillance, the new guidelines “will probably have little effect on food labels in the U.S. for the foreseeable future,” the LA Times reported. Consumers may slowly begin to see some changes to labels on imported food products, but the FDAs regulatory processes will likely remain unchanged unless the United States adopts the GM food labeling guidelines.

Fuerst Ittleman will continue to monitor changes to the regulation of genetically modified food products. For more information, contact us at contact@fidjlaw.com.

General Reinsurance Corp. Settles With OFAC Over Alleged Violations of Iranian Transactions Regulations

On June 29, 2011, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury announced that it had reached a settlement with General Reinsurance Corporation (“General”) over alleged violations of the Iranian Transaction Regulations (“ITR”). The alleged violations of the IRT highlight the broad reach and complexity of the sanctions on trade with Iran. General information regarding economic sanctions against Iran can be found at OFACs website here.

The ITR, which are found at 31 C.F.R. part 560, were promulgated pursuant to the International Emergency Economic Powers Act and are administered by OFAC. 31 C.F.R. § 560.206 prohibits U.S. persons from “financing, facilitating, or guaranteeing” goods, technology or services to Iran. Additionally, 31 C.F.R. § 560.208 prohibits U.S. persons from approving, financing, facilitating, or guaranteeing any transaction by a foreign person where the transaction performed would be prohibited under the IRT if performed by a U.S. person.

Similar to our previous reports of IRT settlement agreements, although General did not directly engage in business with Iran, due to the nature of its business relationships with other entities who were engaged in business in Iran, General was found to be in violation of the IRT. OFAC alleged that the violations consisted of two reinsurance claim payments to the Steamship Mutual Underwriting Association Limited for losses arising from vessel operations of the National Iranian Tanker Company which Steamship Mutual insured. According to OFAC, General made these excess of loss claim payments pursuant to its facultative reinsurance obligation to Steamship Mutual for the coverage period of June 16, 1998 to February 20, 2002. (Reinsurance is an insurance policy taken out by an insurance company on an insurance policy. Reinsurance is usually purchased by the original insurer to mitigate its own risks associated with payment of policies. The reinsurance is used to cover and pay the original policy. In a facultative reinsurance agreement the reinsurer assumes all or part of the risks associated with a particular policy.) Consequently, due to the broad reach of the IRT, and even though General had no direct business relationships with any Iranian business, Generals reinsurance activities were deemed by OFAC to be a violation.

OFAC announced that General has paid $59,130 in penalties for its violations. According to OFAC enforcement guidelines, the base penalty associated with such a violation is $131,424. However, this penalty was lowered because: 1) General voluntarily disclosed its violations and substantially cooperated with OFAC; 2) General is the largest reinsurer in the United States; 3) the violations were the result of personnel violating Generals policies and procedures; and 4) General has not previously been subject to OFAC penalties. Additionally, General has installed enhanced sanctions compliance software and implemented new training programs regarding sanctioned transactions. A copy of OFACs announcement can be read here.

For more information regarding OFAC and strategies on maintaining compliance with federal regulations, please contact Fuerst Ittleman at 305-350-5690 or contact@fidjlaw.com

Formaldehyde Containing Hair Straighteners Come Under Scrutiny, FDA Urged to Take Action

On May 6, 2011, Rep. Jan Schakowsky, joined by nine other members of the U.S. House of Representatives, sent a letter to the FDA expressing concerns over the use of keratin hair-straightening products which contain high levels formaldehyde. Excess exposure to formaldehyde, a chemical classified by the EPA as a probable carcinogen, can irritate the skin, eyes, and lungs, and can cause breathing problems. Additionally, exposure has been linked to nose and throat cancer and leukemia. A copy of the Congresswomans letter can be read here.

Under the Federal Food Drug and Cosmetic Act, (“FDCA”), 21 U.S.C. § 301 et. seq., the FDA is granted the authority to regulate cosmetics. In accordance with 21 U.S.C. §§ 361 and 362, the FDCA, requires that cosmetics must be neither adulterated nor misbranded. However, unlike medical devices and drugs, cosmetics are not required to receive premarket approval from the FDA prior to marketing. Additionally, cosmetics marketed solely to professionals for salon use are not required to have labeling listing the products ingredients.

Rep. Schakowskys letter comes as formaldehyde based products have been under increased scrutiny. On October 5, 2010, Rep. Earl Blumenauer wrote a letter to the FDA urging it to investigate several hair straightening products labeled as “formaldehyde-free” for possible misbranding under the FDCA. Those products, while technically free of formaldehyde, contain chemicals such as methylene glycol which, when combined with water, creates and releases formaldehyde. In April 2011, the Federal Occupational Safety and Health Administration (“OSHA”) issued a Hazard Alert advising salons to discontinue use of formaldehyde and methylene glycol-based hair straightens. Additionally, in June 2011, the Cosmetic Ingredient Review (“CIR”), an independent industry-funded organization which reviews the safety of cosmetic ingredients, released a tentative conclusion that formaldehyde and methylene glycol are unsafe for use in hair smoothing products. A full study by CIR is expected this September.

Currently, FDA regulations do not prohibit the use of formaldehyde as a cosmetic ingredient and there are no set limits on the amount allowable in products. However, OSHA requires that if a formaldehyde based product is used which contains more than 0.1% formaldehyde, the manufacturer must list the substance on the label and address safe work practices on a material safety data sheet that accompanies the product. Additionally, CIR has recommended that formaldehyde or methylene glycol levels in hair straightening products be no greater than .074%. As a comparison, the products currently on the market which have been tested by OSHA for formaldehyde range from anywhere between 4.85 to 10.6 %.

Rep. Schakowskys letter requests that the FDA: 1) issue a voluntary recall of all formaldehyde based hair straighteners which have already been tested to have levels of formaldehyde greater than OSHA limits; 2) conduct testing of all hair straighteners available on the market to determine formaldehyde levels; and 3) require warning labels for any hair straightener that contains formaldehyde. The letter also asks the FDA to investigate hair straightening products labeled “formaldehyde free” for possible misbranding violations as well as to review and consider a ban on formaldehyde and formaldehyde releasing chemicals from hair straightening products.

Fuerst Ittleman will continue to monitor the progress of these issues. For more information, contact us at contact@fidjlaw.com.