In an interim final rule (IFR) announced March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) dramatically narrowed the scope of the Corporate Transparency Act (CTA). Under the IFR, which is effective...more
3/27/2025
/ Beneficial Owner ,
Corporate Governance ,
Corporate Transparency Act ,
Deadlines ,
Domestic Corporations ,
FinCEN ,
Foreign Corporations ,
Interim Final Rules (IFR) ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements
Only a week after announcing a new deadline of March 21, 2025, for filings under the Corporate Transparency Act (CTA), the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it...more
In the latest twist involving the Corporate Transparency Act (CTA), the only nationwide injunction still in effect that barred enforcement of the CTA’s filing deadlines (Smith vs. U.S. Department of the Treasury) was stayed...more
2/20/2025
/ Appeals ,
Beneficial Owner ,
Corporate Transparency Act ,
Filing Deadlines ,
FinCEN ,
National Security ,
Popular ,
Regulatory Requirements ,
Reporting Requirements ,
Small Business ,
Stays ,
U.S. Treasury
In an unusual turn of events, the Fifth Circuit Court of Appeals has reversed itself and put the Corporate Transparency Act (CTA) back on hold....more
12/31/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Compliance ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays ,
Time Extensions
Businesses that are not exempt under the Corporate Transparency Act (CTA) now have less than three weeks until the deadline for their first mandatory filing of beneficial ownership information....more
12/27/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Compliance ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Reporting Requirements ,
Stays ,
Time Extensions
On December 3, 2024, a Texas federal district court issued a preliminary injunction blocking enforcement of the Corporate Transparency Act (CTA). The Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) has...more
12/12/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Constitutional Challenges ,
Corporate Governance ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements
If your business has not yet focused on the Corporate Transparency Act (CTA), it is time to do so. Every entity formed or registered in the U.S. before January 1, 2024, must file beneficial ownership information (BOI) reports...more
8/30/2024
/ Anti-Money Laundering ,
Beneficial Owner ,
Compliance ,
Constitutional Challenges ,
Corporate Transparency Act ,
Financial Crimes ,
FinCEN ,
New Guidance ,
Popular ,
Regulatory Requirements ,
Reporting Requirements
Starting January 1, 2024, many companies operating in the U.S. will be required to gather and report ownership and control information to the Department of Treasury's Financial Crimes Enforcement Network (FinCEN)....more
The Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) recently issued final regulations to implement the reporting requirements under the federal Corporate Transparency Act (CTA). The CTA aims to further...more
11/29/2022
/ Anti-Money Laundering ,
Beneficial Owner ,
Compliance ,
Compliance Dates ,
Corporate Transparency Act ,
Corruption ,
Financial Crimes ,
FinCEN ,
Fraud ,
National Security ,
Regulatory Requirements ,
Reporting Requirements ,
Terrorist Financing ,
Terrorist Financing Regulations
In a series of FAQs issued last spring, the Small Business Administration (SBA) made clear that it would review the certification made by Paycheck Protection Program (PPP) borrowers of $2 million or more that “[c]urrent...more
11/9/2020
/ Audits ,
Borrowers ,
CARES Act ,
Certification Requirements ,
Coronavirus/COVID-19 ,
Federal Loans ,
Good Faith ,
Liquidity ,
Loan Repayment Issues ,
Paycheck Protection Program (PPP) ,
SBA ,
SBA Lending Programs
The Small Business Administration (SBA) recently released a procedural notice concerning when a borrower of a Paycheck Protection Program (PPP) loan may forgo SBA approval in connection with a merger or acquisition. The...more
10/16/2020
/ Acquisitions ,
Administrative Procedure ,
Certifications ,
Change in Control ,
Change of Ownership ,
Coronavirus/COVID-19 ,
False Claims Act (FCA) ,
Mergers ,
Paycheck Protection Program (PPP) ,
SBA ,
SBA Lending Programs ,
Small Business
The Small Business Administration (SBA) released on June 16 two revised loan forgiveness applications (each, along with separate instructions, available here). Borrowers of a Paycheck Protection Program (PPP) loan must use...more
On June 3, Congress passed the Paycheck Protection Program Flexibility Act (PPPFA). The PPPFA aims to address some issues that borrowers and industry groups had raised regarding the PPP as originally passed on March 27,...more
The U.S. moved forward this week with its threat to place tariffs on $200 billion worth of Chinese imports. The tariffs will kick in this Monday and increase duties by 10 percent on more than 5,700 items, a massive list that...more
The trade spat between the U.S. and China is escalating, with the Trump administration now looking to quadruple the value of Chinese products affected by American tariffs.
Last week, we wrote about the U.S. beginning to...more
The United States Trade Representative (USTR) Office has confirmed that tomorrow – Friday, July 6 – remains the date that U.S. Customs and Border Protection will start collecting Section 301 tariffs on more than 1,000 items...more
State and local governmental entities (“Governments”) nationwide will soon face new financial statement disclosure requirements regarding existing tax incentive agreements. While the GASB encourages Governments to begin...more